77 west jackson boulevard chicago, il 60604 ...14. section 4.4.3, ics for land transferred to will...

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5

77 WEST JACKSON BOULEVARD CHICAGO, IL 60604·3590

EPA Region 5 Records ctr.

SEP 28 2009 1IIIIIIII 341878

REPLY TO THE ATIENTION OF:

S-6J

Mr. Arthur Holz Commander's Representative Joliet Anny Ammunition Plant 29401 South Route 53 Wilmington, IL 60481-9979

Subject: U.S. EPA Concurrence: Final Second Five Year Review Report for the Soils Operable Unit and the Groundwater Operable Unit, Joliet Army Ammunition Plant, Wilmington, Illinois, August 2009

Dear Mr. Holz:

The U.S. Environmental Protection Agency (USEPA) has reviewed the subject Final Second Five Year Review Report for the Soils Operable Unit and the Groundwater Operable Unit, Joliet Army Ammunition Plant (Report), which was prepared by Aerostar Environmental Services, Inc. for the U.S. Anny Corps of Engineers, Louisville District. USEPA's review of the Report was focused on verifying that our comments on the draft final version of the Report were adequately and appropriately incorporated into the fInal document.

USEPA substantially concurs with the fIndings and recommendations presented in the Report. However, based upon our review ofdocumentation provided in response to our comments on the draft fInal version of the document, USEPA also notes outstanding issues relative to the implementation and documentation of institutional controls. These issues are identifIed in the attached comments on the Final Report. Based upon our review, USEPA considers the remedies reviewed in the Final Second Five Year Review Report for the Soils Operable Unit and Groundwater Operable Unit for the Joliet Anny Ammunition Plant to be protective in the short-term. In order for the remedies to be protective in the long-term, the institutional controls issues will need to be resolved. USEPA requests that the Anny develop a plan and schedule for the resolution of these issues within six months.

Recycled/Recyclable' Printed With Vegetable 011 Based Inks on 100% Recycled Paper (50% Postconsumer)

By this letter, and with the inclusion of the attached comments addressing actions that USEPA considers necessary to fully implement and document institutional controls, USEPA concurs with the Final Second Five Year Review Report for the Soils Operable Unit and the Groundwater Operable Unit, Joliet Army Ammunition Plant.

Sincerely,

Richard C. Karl Director Superfund Division

Attachment

USEPA Comments on the Final Second Five Year Review Report for the Soils Operable Unit and the Groundwater Operable Unit, Joliet Army Ammunition

Plant, Wilmington, Illinois, August 2009

I. Soil Operable Unit

I. Section 4.2.1.12. Site M7. par. 2. p. 73 - The text does not state whether the property was transferred, or whether deed restrictions or land use restrictions have been implemented.

2. Section 4.2.2.4.• Site LII - It is not clear from the text whether LII was transferred to the industrial park.

3. Section 4.2.2.5. Site L23A. par. 5. o. 79 - Land use restrictions are not in place until property is transferred.

4. Section 4.2.2.6. Site M4 - See comment 3.

5. Section 4.2.2.8. Site MI2 - See comment 3.

6. Section 4.2.6.2.. Site L4 - See comment 3.

7. Section 4.2.6.3.. Site MI - The text states that land use restrictions will be developed. Add this infonnation to the Table listing the work that needs to be done.

8. Section 4.2.6.5.. Site MIl - See comment 7.

9. Section 4.2.6.6.. Site M13 - See comment 7.

10. Table II. p. 100 - Note that certification ofcompliance with institutional controls or equivalent needs to be submitted annually.

II. Section 4.3 .. System Operation/OPeration and Maintenance - Note that there are maintenance costs for institutional controls; inspections and annual reports, for example.

12. Section 4.4.2.1., Adherence to ICs - Propertv Conveyed to JADA. par. 2 - Add comments concerning the CenterPoint annual report to the table listing what issues need to be addressed (e.g., What areas do the annual reports cover? What is the status of parcels CenterPoint has conveyed?).

13. Section 4.4.2.1. Adherence to ICs - Propertv Conveyed to JADA. par. 3 - Add . comments concerning Island City Development industrial park to the table listing what

issues need to be addressed. None of the annual reports have been filed.

14. Section 4.4.3, ICs for Land Transferred to Will County, par. 3 and Table 15 - There is no requirement for an annual report in the Will County Deed. This needs to be stated in the Table listing issues that need to be addressed. Also the Will County Deed does not have all of the residential limits or ground water limits stated in Table 15. In fact, the Deed states that the water can be used for drinking if it meets the SOWA requirements and state law. The ROD does not allow this exception. The ROD also has other residential and ground water limitations that are in Table 15, but not the Deed. Compare the Deed to the Table and correct the Table. If the Deed does not list all the restrictions, then this needs to be addressed.

15. Section 4.4.4, Summary oncs for Soil Sites, par. 1, sentence 1 - This sentence is too broadly stated, See Comment 14.

16. Section 4.4.4, Summary oncs for Soil Sites, par. 3 - The text notes that no written notice was provided to the Anny from CenterPoint with respect to the assignment of the duties and obligations imposed by the MOA from CenterPoint to subsequent property owners, and no written concurrence has been provided by the Anny and that no annual reports have been received from JADA concerning JADA-owned property in the Mfg. area These issues need to be addressed and should be listed in the Table concerning items that need to be carried out.

17. Section 4.4.5., Recommendations to Enhance Implementation of ICs, par. 4 - Annual reports and written notice and concurrence have not been provided by JADA for property owned in the LAP area See comment 16.

18. Table 16 - Under current site status it does not say that the recommendations from the last 5 year review were addressed. The table needs to state that the specific recommendations were carried out (e.g., padlock placed on gate).

19. Section 7.1.1.3., p. 124, par. 4 - The text is unclear. It states that the gate was not locked during 2008 inspection, and then says that areas are gated and locked. If the unlocked gate has been addressed, please indicate that.

20. Section 7.4, Technical Assessment Summary, p. 131 - The text states that there is no other information calling into question the protectiveness of the remedies. However, at least some I.e. issues, as noted in the above comments, need to be addressed.

21. Table 17. p. 132 - As discussed in the above comments, there are additional issues that need to be addressed in the Table. See comments 7 - 9, 10, and 12 - 16. Also compare this table to similar Table for the Groundwater Operable Unit (GOU) (See comment 31).

22. Table 18. p. 135 - As noted in the above comments, additional issues need to be addressed in the Table. See comments 7-9, 10, and 12-16. Also compare this table to the similar table for the GOU (See comment 32). In addition, require an institutional control plan to address the outstanding IC issues.

II. Groundwater Operable Unit

23. Section 4.4. Institutional Controls. p. 38, par. 4. second sentence - Please edit. The remaining parcels to be transferred are not described in previous deeds. When the remaining parcels are transferred to an entity that is not the federal government a new deed describing the parcels being transferred and the deed restrictions being imposed will need to be executed and recorded.

24. Section 4.4.3, ICs for Contaminated Areas Transferred to Will County, p. 44, last par. - The Will County Deed does not prohibit the use of groundwater within the glacial drift and Silurian dolomite for human consumption. It provides an exception saying it can be used if the water complies with the SDWA and applicable state law. This exception was not contemplated by the ROD and needs to be addressed in an institutional control plan.

25. Table 10. p. 45 - Edit the table to reflect Will County Deed. The Will County Deed does not have all the IC objectives listed in the table. The first column of the table actually refers to the Superfund Sites as a whole and not just to the parcels deeded to Will County. If the Will County Deed does not reflect all of the IC objectives, then this issue will need to be addressed in an institutional control plan.

26. Section 4.4.4. Summary ofICs for GOD Sites - A robust set ofICs has not been designed and implemented for all transferred properties. See Comments 24 and 25 concerning Will County. Also, no annual reports are required for Will County. In addition, the annual reports for other transferred parcels have not been filed or provide inadequate infonnation to judge whether the ICs are being complied with. In addition, the Army is apparently not being notified of transfers of property from, for example, CenterPoint to other entities and concerning the Island City Development.

27. Section 4.4.5, Recommendations to Enhance Implementation ofICs - This section contains additional recommendations which need to be listed as items that need to be carried out.

28. Section 7.3.2.2, Site M5, Ouestion B: Are the Exposure Assumptions, Toxicity Data. Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of the Remedy Still Valid? - It is not clear whether Site M5 been transferred from the Army and, if so, who is responsible for the ICs.

29. Section 7.3.5.2, Site M8, Question B: Are the Exposure Assumptions, Toxicity Data. Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of the Remedy Still Valid? - See Comment 28.

'. ..'

30. Section 7.4.2.2.. Site MI0. Question B: Are the Exposure Assumptions. Toxicity Data. Cleanup Levels. and Remedial Action Objectives (RAOs) Used at the Time of the Remedy Still Valid? - It is not clear whether Site MI0 been transferred from the Army and, if so, who is responsible for the ICs.

31. Table 17. Issues - Add the other issues raised by the five year review, including, lack ofannual reports, inadequate annual reports, lack ofnotification of transfer ofproperties (this also would include the need to determine if transferee is notified ofdeed restrictions and has responsibilities concerning annual reports and deed restrictions), and concerns about the Will County Landfill deed restrictions. See Section 4.4.5, which discusses some of these issues and makes recommendations. Also see comments 21 and 24-27.

32. Table 18. - Recommendations and Follow-up Actions - Address all of the IC issues and require an institutional control plan to address outstanding issues - see Comment 31. Also see Section 10.1, par. 3, which discusses the need for evaluation activities, comment 22 and comments 24-27.

33. Please note that in attachment 12 of the GOU there are apparently 5 different deeds from the Army to JADA, but in the SOU attachment there are only 3 different deeds from the Army to JADA. Table 9, page 43 (GOO) only lists 3 different deeds for transfer of property to JADA Please address this inconsistency.

_______________________ ____________________

Final

Five-Year Review Report

Second Five-Year Review Report Soils Operable Unit

for Joliet Army Ammunition Plant (JOAAP)

Wilmington, Illinois

Contract Number: W912QR-08-D-0009 Delivery Order 0002

August 2009

Prepared for: United States Army Corps of Engineers

Louisville District 600 Dr. Martin Luther King Jr. Place, Room 921

Louisville, Kentucky 40202

Prepared by: Aerostar Environmental Services, Inc. 11181 St. Johns Industrial Parkway, N

Jacksonville, Florida 32246 AES Project #0108-223-15

Approved by: Date:

Arthur Holz Joliet Army Ammunition Plant Site Manager/Commander’s Representative

Certification 4

CONTRACTOR STATEMENT OF INDEPENDENT TECHNICAL REVIEW

US Army Corps of Engineers LOUISVILLE DISTRICT

The firm of AEROSTAR has completed the technical review of the Final Second Five-Year Review Report, Soil Operable Unit, for the Joliet Army Ammunition Plant (JOAAP), Wilmington, Illinois. Notice is hereby given that an independent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project, as defined in the Quality Control Plan. During the independent technical review, compliance with established policy principles and procedures, utilizing justified and valid assumptions, was verified. This included review of assumptions; methods, procedures and material used in analyses; the appropriateness

___________________________________ Independent Technical Review Team Leader

Gerald B. Girardot, P.G.

_8/28/09_______ Date

Rick Levin, P.G.

Significant concerns and the explanation of the resolution are as follows:

None

A noted above, all concerns resulting from independent technical review of the project have been considered.

of data used and level of data obtained; and reasonableness of the results including whether the product meets the customer’s needs consistent with the law and existing USACE policy.

______________________________________ _8/28/09_______ Project Manager Date

__________________________________ _8/28/09_______ Principal Date K. Dawn Blackledge

August 2009 Final – Second Five-Year Review Report W912QR-08-D-0009/0002 JOAAP – Soil Operating Unit

Final

Second Five-Year Review Report

TABLE OF CONTENTS

TABLE OF CONTENTS LIST OF ACRONYMS

EXECUTIVE SUMMARY ...........................................................................................................1

1.0 INTRODUCTION ..............................................................................................................9

2.0 SITE CHRONOLOGY ....................................................................................................11

3.0 BACKGROUND...............................................................................................................17 3.1 General Site Background .............................................................................................17 3.1.1 Physical Characteristics .............................................................................................................. 17 3.1.2 Land and Resource Use .............................................................................................................. 17 3.1.3 History of Contamination ........................................................................................................... 18 3.1.4 Summary of Initial Response...................................................................................................... 19 3.1.5 General Basis for Taking Action ................................................................................................ 23

3.2 Site Specific Background Information........................................................................24 3.2.1 Site L1 ........................................................................................................................................ 25 3.2.2 Site L2 (Explosive Burning Grounds) ........................................................................................ 27 3.2.3 Site L3 (Demolition Area) .......................................................................................................... 28 3.2.4 Site L4 (Landfill Area) ............................................................................................................... 30 3.2.5 Site L5 (Salvage Yard) ............................................................................................................... 30 3.2.6 Site L6 ........................................................................................................................................ 32 3.2.7 Site L7 ........................................................................................................................................ 33 3.2.8 Site L8 ........................................................................................................................................ 34 3.2.9 Site L9 ........................................................................................................................................ 34 3.2.10 Site L10....................................................................................................................................... 35 3.2.11 Site L11 (Test Site)..................................................................................................................... 36 3.2.12 Site L14....................................................................................................................................... 37 3.2.13 Site L16....................................................................................................................................... 37 3.2.14 Site L17 (Group 7)...................................................................................................................... 38 3.2.15 Site L23A (Disposal Pit)............................................................................................................. 38 3.2.16 Site M1 (Southern Ash Pile)....................................................................................................... 39 3.2.17 Site M2 (Explosive Burning Ground)......................................................................................... 40 3.2.18 Site M3 (Flashing Grounds) ....................................................................................................... 40 3.2.19 Site M4 (Lead Azide Area)......................................................................................................... 42 3.2.20 Site M5 (Tetryl Production Area) ............................................................................................... 42 3.2.21 Site M6 (TNT Ditch Complex)................................................................................................... 44 3.2.22 Site M7 (Red River Area)........................................................................................................... 46 3.2.23 Site M8 (Acid Manufacturing Area)........................................................................................... 47

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3.2.24 Site M9 (Northern Ash Pile)....................................................................................................... 47 3.2.25 Site M11 (Landfill) ..................................................................................................................... 49 3.2.26 Site M12 (Sellite Manufacturing Area) ...................................................................................... 50 3.2.27 Site M13 (Gravel Pit) ................................................................................................................. 51 3.2.28 Site M16 (Motor Pool Area)....................................................................................................... 51

4.0 REMEDIAL ACTIONS...................................................................................................53 4.1 Remedy Selection ..........................................................................................................54 4.1.1 SRU1: Explosives in Soil – Excavation/Treatment ................................................................... 54 4.1.2 SRU2: Metals in Soil – Excavation/Disposal ............................................................................ 54 4.1.3 SRU3: Explosives and Metals in Soil – Excavation/Disposal ................................................... 55 4.1.4 SRU4: Excavation/Incineration and Disposal ........................................................................... 55 4.1.5 SRU5: Organics in Soil – Excavation/Treatment ...................................................................... 55 4.1.6 SRU7: Removal and Recycle and Disposal ............................................................................... 56 4.1.7 No Further Action Sites .............................................................................................................. 56

4.2 Remedy Implementation ..............................................................................................56 4.2.1 SRU1 Soils ................................................................................................................................. 57 4.2.2 SRU2 Soils ................................................................................................................................. 73 4.2.3 SRU3 Soils ................................................................................................................................. 82 4.2.4 SRU4 Soils ................................................................................................................................. 84 4.2.5 SRU5 Soils ................................................................................................................................. 87 4.2.6 SRU6 Soils ................................................................................................................................. 89 4.2.7 SRU7 Soils ................................................................................................................................. 95 4.2.8 Site M4 Bioremediation Facility ................................................................................................ 95 4.2.9 Implemented Institutional Controls and Access Controls .......................................................... 99

4.3 System Operation/Operation and Maintenance ........Error! Bookmark not defined. 4.3.1 SRU1 Soils ..................................................................................Error! Bookmark not defined. 4.3.2 SRU2 Soils ............................................................................................................................... 102 4.3.3 SRU3 Soils ............................................................................................................................... 102 4.3.4 SRU4 Soils ............................................................................................................................... 102 4.3.5 SRU5 Soils ............................................................................................................................... 103 4.3.6 SRU6 Soils ............................................................................................................................... 103 4.3.7 SRU7 Soils ............................................................................................................................... 104 4.3.8 No Further Action Sites ............................................................................................................ 104 4.3.9 Summary of Costs for Operation/Operation and Maintenance................................................. 104

4.4 Institutional Controls..................................................................................................104 4.4.1 ICs for Remediated Areas Transferred to the USDA FS .......................................................... 106 4.4.2 ICs for Remediated Areas Transferred to the State (JADA) .................................................... 109 4.4.3 ICs for Remediated Areas Transferred to Will County ............................................................ 111 4.4.4 Summary of ICs for Soil Sites .................................................................................................. 113 4.4.5 Recommendations to Enhance Implementation of ICs............................................................. 114

5.0 PROGRESS SINCE LAST FIVE YEAR REVIEW ...................................................116

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6.0 FIVE-YEAR REVIEW PROCESS...............................................................................120 6.1 Administrative Component........................................................................................120 6.2 Community Involvement............................................................................................120 6.3 Document Review........................................................................................................120 6.4 Data Review .................................................................................................................121 6.4.1 Data Review for Soil Operable Unit RA Activities .................................................................. 121 6.4.2 Data Review for Site M4 Bioremediation Facility Operations................................................. 121

6.5 Site Inspection .............................................................................................................121 6.6 Interviews.....................................................................................................................122

7.0 TECHNICAL ASSESSMENT ......................................................................................123 7.1 QUESTION A: Is the Remedy Functioning as Intended by the Decision

Documents? ....................................................................................................................123 7.1.1 SRU1 Soils ............................................................................................................................... 123 7.1.2 SRU2 Soils ............................................................................................................................... 124 7.1.3 SRU3 Soils ............................................................................................................................... 126 7.1.4 SRU4 Soils ............................................................................................................................... 127 7.1.5 SRU5 Soils ............................................................................................................................... 127 7.1.6 SRU6 Soils ............................................................................................................................... 128 7.1.7 SRU7 Soils ............................................................................................................................... 129 7.1.8 Site M4 Bioremediation Facility .............................................................................................. 130 7.1.9 No Further Action Sites ............................................................................................................ 130

7.2 QUESTION B: Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOS) Used at the Time of the Remedial Selection Still Valid? ......................................................................................................................130

7.3 QUESTION C: Has Any Other Information Come to Light That Could Call Into Question The Prptectiveness of the Remedy? .............................................................131

7.4 TECHNICAL ASSESSMENT SUMMARY................................................................131

8.0 ISSUES ............................................................................................................................132

9.0 RECOMMENDATION AND FOLLOW-UP ACTIONS...........................................134

10.0 PROTECTIVE STATEMENTS ...................................................................................136

11.0 NEXT REVIEW .............................................................................................................139

12.0 REFERENCES ...............................................................................................................140

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LIST OF TABLES

Table 1 Chronology of Site Events ................................................................................................ 11 Table 2 Contaminants of Concern ................................................................................................ 19 Table 3 Prevalent Soil and Groundwater Explosive COC ............................................................. 23 Table 4 Summary of Site Remedial Action Status ........................................................................ 25 Table 5 SRU1 Sites - Excavated Soil Volumes ............................................................................. 58 Table 6 SRU1 Sites - Excavated Concrete Volumes ..................................................................... 58 Table 7 Site M6 Excavation Volumes ........................................................................................... 71 Table 8 SRU2 Sites - Excavated Soil Volumes ............................................................................. 74 Table 9 Summary of Soil Treated at the Site M4 Bioremediation Treatment Facility .................. 98 Table 10 Site M4 BTF Bioremediation Reports .............................................................................. 99 Table 11 Summary of Implemented Institutional and Access Controls ........................................ 100 Table 12 Annual System Operations/O&M Costs for the SOU .................................................... 104 Table 13 Institutional Controls Summary for Lands Transferred to USDA .................................. 108 Table 14 Institutional Controls Summary for Lands Transferred to JADA ................................... 110 Table 15 Institutional Controls Summary for Lands Transferred to Will County ......................... 112 Table 16 Actions Taken Since the Last Five-Year Review ........................................................... 117 Table 17 Issues Identified During Second Five-Year Review ....................................................... 132 Table 18 Recommendations and Follow-up Actions ..................................................................... 134

ATTACHMENTS

Attachment 1 Site Location Map Attachment 2 JOAAP Site Map Attachment 3 List of Documents Reviewed Attachment 4 Applicable or Relevant and Appropriate Requirements (ARARs) Attachment 5 Site Inspection Forms Attachment 6 Interview Summaries Attachment 7 Copies of Annual Certification Attachment 8 Copy of Public Notification Attachment 9 Documentation of Adherence to Institutional Controls Attachment 10 Comments Received from the Community and Support Agencies

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LIST OF ACRONYMS

AEROSTAR Aerostar Environmental Services, Inc. AFR Acid Fume Recovery AOP Ammonia Oxidation Plant ARARs Applicable or Relevant and Appropriate Requirements ASTs Above ground storage tanks BGS Below ground surface BNA Base Neutral Acids BNSF Burlington Northern Santa Fe BTF Bioremediation Treatment Facility BTEX Benzene, toluene, ethylbenzene, xylene CERCLA Comprehensive Environmental Response, Compensation, and Liability Act C&D construction and demolition CFR Code of Federal Regulation CHPPM Center for Health Promotion and Preventive Medicine COC Contaminants of Concern CY cubic yards DNT Dinitrotoluene ECOP Environmental Condition of Property ESD Explanation of Significant Difference FFA Federal Facilities Agreement FFS Focused Feasibility Study FOST Finding of Suitability to Transfer FS Feasibility Study FY Fiscal Year GMZ Groundwater Management Zone GOUs Groundwater Operable Units HDPE High Density Polyethylene HMX Cyclotetramethylenetetranitramine HRS Hazard Ranking System IAC Illinois Administrative Code IDNR Illinois Department of Natural Resources IDOT Illinois Department of Transportation IEPA Illinois Environmental Protection Agency IOC Industrial Operations Command JOAAP Joliet Army Ammunition Plant LAP Load Assemble Package LDR Land Disposal Restriction LRGs lower remediation goals MEC Munitions and Explosives of Concern MFG Manufacturing Area mg/kg milligrams per kilogram MKM MKM Engineers, Inc. MMRP Military Munition Response MNTP Midewin National Tallgrass Prairie MWH MWH Americas, Inc. NFA No Further Action NCP National Contingency Plan NPDES National Pollutant Discharge Elimination Systems NPL National Priorities List

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NT Nitrotoluene O&M Operation and Maintenance OHM OHM Remediation Services Corporation OUs Operable Units PACM Potential Asbestos Containing Material PAHs Polynuclear Aromatic Hydrocarbons PCB Polychlorinated biphenyl PL Public Law ppm parts per million PRGs Project Remedial Goals PVC Polyvinyl Chloride R&D Research and Development RA Remedial Action RAB Restoration Advisory Board RAOs Remedial Action Objectives RCRA Resource Conservation & Recovery Act RD Remedial Design RAWP Remedial Action Work Plan RDF Recycling Disposal Facility RDX Cyclotrimethylenetrinitramine RGs Remedial Goals RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision Sellite Sodium sulfite SF Square feet SOU Soil Operable Unit SAP Sampling and Analysis Plan SRUs Soil Remediation Units SVOC Semi-volatile Organic Compounds TCLP Toxicity Characteristic Leaching Procedure TNB Trinitrobenzene TNT Trinitrotoluene TPH Total petroleum hydrocarbons TSCA Toxic Substances Control Act URGs upper remediation goals USACE US Army Corps of Engineers USAEC US Army Environmental Center USATHAMA US Army Toxic and Hazardous Materials Agency USDA/FS US Department of Agriculture/Forest Service USAEHA US Army Environmental Hygiene Agency USEPA US Environmental Protection Agency USFWS US Fish and Wildlife Service USTs Underground storage tanks UV ultraviolet UXO Unexploded Ordnance VOC Volatile Organic Compounds WCLF Will County Landfill WCVEP Waste Classification and Volume Estimates Plan

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EXECUTIVE SUMMARY

Aerostar Environmental Services, Inc. (AEROSTAR) has been contracted by the United States Army Corps of Engineers (USACE) to conduct the statutory Second Five-Year Review of the Soils Operable Unit (SOU) at the Joliet Army Ammunition Plant (JOAAP) in Wilmington, Illinois. AEROSTAR completed the work on behalf of USACE between October 2008 and April 2009 under contract W912QR-08-D-0009 Delivery Order 0002.

The Second Five-Year Review of the SOU, pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section (§) 121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), was performed to evaluate the effectiveness of the remedies implemented at the site and to assess the current and anticipated future protectiveness of human health and the environment at JOAAP. The trigger action for the Second Five-Year Review was the end of the First Five-Year Review Period for the SOU at JOAAP on May 04, 2004.

The October 1998 Record of Decision (ROD), Soil and Groundwater Operable Units, Manufacturing (MFG) and Load Assemble Package (LAP) Areas, National Priority List (NPL) Sites (U.S. Army, October 1998) identified final Remedial Goals (RGs) and selected remedies for 20 SOU sites within JOAAP. In addition, interim remedies were selected for 14 SOU sites within JOAAP in the October 1998 ROD. Final remedies were identified for these 14 SOU sites in the June 2004 ROD (U.S. Army, June 2004).

Remedial Design/Remedial Action (RD/RA) work plans, submitted to the USACE in April 1999 and October 2005, included technical design of Remedial Action (RA) activities conducted at the 28 contaminated sites with selected remedies and final RGs.

The current status of the 28 final RA sites identified in the October 1998 and June 2004 RODs is summarized as follows:

� Sixteen sites (L1, L4, L7, L8, L9, L10, L11, L14, L16, L17, M2, M5, M6, M7, M8, and M9) have achieved closure status for soil-related contaminants of concern (COC).

� Ten sites (L2, L3, L5, L23A, M1, M3, M4, M11, M12, and M13) have completed remedial actions, but have not received closure status for soil-related COC.

� No Further Action (NFA) sites (L6 and M16) with impacted soils that do not allow for unlimited use and unrestricted exposure have institutional controls (deed restrictions) effectively implemented at each site.

According to the data reviewed, site inspections, interviews, and technical assessment, the selected remedies are functioning as intended by the 1998 and 2004 RODs. RA activities have been implemented successfully as verified by confirmation sampling and routine inspections at the sites.

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At sites where RA activities have been completed for soil-related COC, RGs have been met and selected remedies are protective of human health and the environment. Potential threats identified in the 1998 and 2004 RODs at these sites have been addressed. Applicable or Relevant and Appropriate Requirements (ARARs) for soils cited in the 1998 and 2004 RODs are being met. At sites where RA activities are complete and the land has been transferred, the new occupier submits certification of compliance for implementation of institutional controls, specified in the property deed, to the Army on an annual basis.

There have been no changes in physical conditions, toxicity factors or exposure assumptions at JOAAP used to establish the baseline risk assessment for COC that would affect the protectiveness of the selected remedies.

There were no operation and maintenance (O&M) issues identified during the Second Five-Year Review that could affect the protectiveness of the selected remedies. There is no other information that could call into question the protectiveness of the remedies. Seven recommendations have been addressed based on the Site Inspection conducted as part of the Second Five-Year Review process.

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Second Five-Year Review Summary Form

1.1.1.1.1 SITE IDENTIFICATION Site name: Joliet Army Ammunition Plant EPA ID: IL7213820460 (Manufacturing Area), IL0210090049

Region: V State: IL City/County: Wilmington / Will

1.1.1.1.2 SITE STATUS

NPL status: � Final G Deleted G Other (specify)

Remediation status (choose all that apply): G Under Construction � Operating � Complete

Multiple OUs?* � YES G NO Construction completion date: N/A

Has site been put into reuse? � YES G NO

1.1.1.1.3 REVIEW STATUS

Lead agency: G EPA G State G Tribe ��Other Federal Agency – U.S. Army

Author name: Gerald B. Girardot Author title: Senior Project Manager Author affiliation: AEROSTAR Environmental

Services, Inc., USACE Consultant Review period:** 05 / 06 / 2004 to 05 / 06 / 2009 Date(s) of site inspection: 10 / 21 / 2008 to 10 / 23 / 2008 Type of review:

� Post-SARA G Pre-SARA G NPL-Removal only G Non-NPL Remedial Action Site G NPL State/Tribe-lead G Regional Discretion

Review number: G 1 (first) � 2 (second) G 3 (third) G Other (specify) __________

Triggering action: G Actual RA Onsite Construction at OU #____ G Actual RA Start at OU#____

G Construction Completion � Previous Five-Year Review Report G Other (specify)

Triggering action date (from WasteLAN): 05 / 06 / 2004 Due date (five years after triggering action date): 05 / 06 / 2009

* [“OU” refers to operable unit.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

3


ISSUES:

This Second Five-Year Review identified six issues related to site operations which are listed below. None of the issues identified affect the long-term protectiveness of the selected remedy at those sites. A summary of the issues is listed below.

Site L3 – The area east of the landfill has no vegetative cover and no silt fence in place to control erosion.

Site L5 - PCB excavation area shown on Figure 3-7 of L5 Draft Closure Report (MWH, March 2008) is not evident as depicted. No significant vegetative cover is established in the excavation area east of the onsite buildings and no silt fence is in place.

Site M11 - The small area of standing water with an oily/rusty sheen at the toe of rip-rap on the west-northwest side of the landfill may be leachate seeping from the landfill. Vegetative cover on cap is excessive, inhibiting inspection of cap integrity. Vegetation beyond rip-rap is not established. Minor surface erosion on the landfill cap was noticed during an O&M inspection. No lock on gate.

Site M13 – Minor animal burrowing (~3 inch diameter) evident in the southeastern area of cap. Vegetative cover on cap is excessive, inhibiting inspection of cap integrity. Minor surface erosion on the landfill cap and a small surveyor hole were noticed during an O&M inspection. No lock on gate.

General - The owners of the Prologis Industrial Park should provide documentation to the U.S. Army, similar to that provided by CenterPoint Industrial Park, to verify that they understand and are in compliance with the institutional controls and deed restrictions placed on their property.

General - The Second Five-Year Reviews for Soil and Groundwater were prepared in accordance with the Comprehensive Five-Year Review Guidance document (USEPA, June 2001). Because remedial actions for the vast majority of Soil Operable Unit Sites were completed during the time between the First and Second Five Year Reviews, combining the documents for the SOU and GOU for the next Five Year Review should be considered to avoid unnecessary redundancy and present the data in an integrated format.

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RECOMMENDATIONS AND FOLLOW-UP ACTIONS:

The following recommendations and follow-up actions are suggested for the issues identified during the Second Five-Year Review.

L3 Install silt fencing around the area without established vegetation to the east of landfill and hydro-seed.

L5 Install silt fencing around the area without established vegetation to the east of the onsite buildings and hydro-seed.

M11

Inspect the cap/ liner on the west-northwest side of the landfill. Collect a surface water sample and soil sample in the vicinity of the oily sheen to be analyzed for any COC that may be present at the landfill. Mow vegetation on the landfill cap as needed. Backfill and seed as necessary to eliminate minor surface erosion. Place lock on gate.

M13 Mow vegetation on the landfill cap as needed. Repair animal burrow holes in cap. Backfill and seed as necessary to eliminate minor surface erosion and the small surveyor hole. Place lock on gate.

General Perform interviews with new owners, operators, or managers, of transferred properties to ensure deed restrictions are being followed and institutional controls implemented at the sites are still effective.

General Consider combining the documents for the SOU and GOU for the next Five Year Review.

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PROTECTIVENESS STATEMENTS:

SRU1 Soils - Bioremediation Sites L1, L2, L7, L8, L9, L10, L14, M2, M3, M5, M6, M7, and L16

Remedial actions at Sites M5, M7, and L16 were completed during the First Five-Year Review. Sites L1, L2, L7, L8, L9, L10, L14, M2, M3 and M6 were completed during the Second Five-Year Review. Potential threats at the sites have been addressed through excavation and bioremediation of explosives contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU2 Soils – Excavation and Disposal Sites L2, L11, L23A, M3, M4, and M12

Remedial action at Site L11 was completed during the First Five-Year Review. Sites L2, L23A, M3, M4, and M12 were completed during this Second Five-Year Review. Potential threats at the sites have been addressed through excavation and disposal of metals contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Sites L3 and L5

Remedial actions at Sites L3 and L5 have been completed, but the closure reports were not available during this review. The selected remedy included excavation and disposal of metals contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU3 Soils – Bioremediation and Disposal, and Excavation and Disposal Sites M3, M5, and M6

Remedial actions at Site M5 were completed during the First Five-Year Review. Sites M3 and M6 were completed during the Second Five-Year Review. Potential threats at the sites have been addressed through excavation and bioremediation of metals and explosives contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

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Site L3Remedial actions at Site L3 have been completed, but the closure report was not available during this review The selected remedy included excavation and disposal of metals contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment. .

SRU4 Soils – Excavation/Incineration and Disposal Sites L1, L7, L8, L9, L10, and L17

Remedial actions at Sites L1, L7, L8, L9, L10, and L17 were completed during the First Five-Year Review. Potential threats at the sites have been addressed through excavation and disposal of PCB-contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Site L5 Remedial actions at Site L5 have been completed, but the closure report was not available during this review. The remedy at Site L5 is expected to be protective of human health and the environment upon completion. The selected remedy included excavation and disposal of PCN contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU5 Soils – Excavation and Bioremediation Site L1

Remedial action at Site L1 was completed during the First Five-Year review. Potential threats at the site have been addressed through excavation and bioremediation of TPH contaminated soils, and implementation of institutional controls in the form of land use restrictions (for lands to be transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Site L5 Remedial actions at Site L5 have been completed, but the closure report was not available during this review. The selected remedy included excavation and bioremediation of TPH contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands to be transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

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SRU6 Soils – Excavation and Disposal Sites L4, M9, and M1

The remedy for Sites L4, M9, and M1 is complete. Potential threats at the sites have been addressed through excavation and disposal of SRU6 contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). The closure report for M1 was not available during this review. Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Sites L3, M11, and M13 Remedial actions at Sites L3 and M13 have been completed, but the closure reports were not available during this review. In the interim, exposure pathways that could result in unacceptable risks are being controlled through access controls in the form of fencing. The selected remedy included capping or excavation and disposal of SRU6 soils and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Further assessment is needed at Site M11 to address the oily sheen noticed at the edge of the rip-rap.

SRU7 Soils – Removal and Recycle or Disposal Sites M8 and M12 Remedial actions at Sites M8 and M12 were completed during the First Five-Year Review. Impacted soils at the site have been addressed through excavation and disposal of surficial sulfur and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Sites M8 and M12 are considered to be protective of human health and the environment.

No Further Action Sites Site L6 Removal actions at Site L6 are complete. Potential threats at the site have been addressed through excavation and disposal of impacted soils, and implementation of institutional controls. Land use restrictions limiting land use for industrial purposes are being implemented. Current data indicates that the RGs established in the October 1998 are satisfied and the site is protective of human health and the environment.

Site M16 Deed restrictions limiting land use for industrial purposes are being enforced. Current data indicates that the RGs established in the October 1998 are satisfied and the site is protective of human health and the environment.

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1.0 INTRODUCTION The United States Army has conducted a Second Five-Year Review of the remedial actions implemented at the Joliet Army Ammunition Plant (JOAAP), Wilmington, Illinois. This review was conducted from October 2008 through February 2009. This report documents the results of the review. The purpose of the five-year review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in five-year review reports. In addition, five-year review reports identify issues found during the review, if any, and identify recommendations to address them.

The United States Army is the lead agency conducting the five-year review. Aerostar Environmental Services, Inc. (AEROSTAR) is preparing this Second Five-Year Review report on behalf of the United States Army Corps of Engineers (USACE) pursuant to Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the National Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

This requirement is further interpreted in the NCP; 40 Code of Federal Regulations (CFR) §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

This is the second five-year review for the JOAAP. The triggering action for this statutory review was the completion of the first five-year review on May 4, 2004. The second five-year review is required due to the fact that hazardous substances, pollutants, or contaminants remain at sites within the Soil Operable Units (SOUs) at JOAAP above levels that allow for unlimited use and unrestricted exposure.

An additional Five-Year Review document is being prepared for the Groundwater Operable Units (GOUs) at JOAAP. The Second Five-Year Review GOU will encompass all sites at JOAAP where groundwater monitoring/remediation have been conducted since initiation of the remedial action on May 5, 1999.

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Much of the background and historical information provided in this report was derived from the Installation Action Plan for JOAPP, the 1998 and 2004 Record of Decisions (RODs), the United States Environmental Protection Agency (USEPA) Comprehensive Environmental Response, Compensation, and Liability Information System Envirofacts Warehouse Website, and the previous Five-Year Review.

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2.0 SITE CHRONOLOGY The chronology presented below begins during early 1940s and ends at the time this report was prepared.

Table 1: Chronology of Site Events

Event Date The JOAAP was constructed to manufacture, load, assemble, pack and ship bombs, projectiles, fuses and supplementary charges.

During World War II

Production of explosives halted; sulfuric acid and ammonium nitrate plants leased out; other production facilities put in layaway status.

1945

Production of explosives reactivated. Korean and Vietnam Wars Gradual decrease in production of explosives during the Vietnam War, then stopped completely.

1977

U.S. Army Environmental Center conducted Installation Assessment and reported potential environmental impacts at former industrial areas.

1978

Installation Restoration Survey conducted by Donohue and Associates and included soil, groundwater, surface water and sediment samples at the Manufacturing (MFG) and Load-Assemble-Packaging (LAP) areas.

1981-1982

Phase II investigation conducted by Donohue and Associates for additional data on previously sampled sites at MFG and LAP to assess off-site impacts. No off site contamination identified.

1983

Pre-remediation sampling at the Red Water Lagoon by Donohue. 1983 Uniroyal (JOAAP's operating contractor) conducted a remedial action to remove contaminated surface water and sediments from Red Water Lagoon at M7.

1983-1985

U.S. Army Environmental Hygiene Agency performed groundwater sampling at selected existing monitoring wells. This was part of JOAAP's Resource Conservation Recovery Act (RCRA) groundwater monitoring program at Site M13 and Red Water Lagoon M-7.

1983-1985

MFG Area at JOAAP proposed for listing on National Priorities List (NPL).

1984

Post-remediation sampling at the Red Water Lagoon by Donohue. 1985 LAP Area at JOAAP proposed for listing on NPL. 1985 Groundwater and surface water samples collected from previously sampled areas at MFG and LAP areas.

1985 and 1986

Dames and Moore presented groundwater and surface water data in a Site Assessment Report which discussed feasibility and need for remediation.

1986

Final NPL Listing for MFG at JOAAP. 1987 Dames and Moore conducts Phase I and II Remedial Investigations (RIs) at MFG Area. Eighteen study areas identified for investigation.

1988-1993

Final NPL Listing for LAP at JOAAP. 1989 Federal Facilities Agreement (FFA) between the Army, USEPA, and Illinois Environmental Protection Agency (IEPA) under CERCLA

1989

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Event Date Section 120 and RCRA Sections 6001, 3008(h), and 3004(v). The FFA was to ensure investigations and remediation would be conducted. USACE investigated underground storage tanks (UST's) at JOAAP. One hundred seven USTs were identified, inventoried, and evaluated.

1989

Most USTs identified by USACE were removed. 1989-1993 Dames and Moore conduces Phase I and II RI's at LAP Area. Thirty-five study areas were investigated.

1991-1994

United States Army Center for Health Promotion and Preventative Medicine (CHPPM) conducted ecological risk assessments to evaluate if site contamination is impacting ecological receptors.

1993 - 1996

United States Army CHPPM issues Phase I Ecological Risk Assessment Report.

1994

Baseline Risk Assessments conducted by Dames and Moore to quantify the potential human health risks posed by contamination identified by the RI's at the MFG and LAP areas.

1994 and 1995

Field Screening of soil for explosives. Results included in Feasibility Studies (FS).

1995

United States Army CHPPM issues Phase II Aquatic Ecological Risk Assessment Report.

1996

Preliminary Remediation Goals (PRGs) established based on the risk assessments by OHM.

1996

USACE conducted removal action for wastes at study area L2. 1996 USACE conducted removal action for polychlorinated biphenyl (PCB) switch boxes from MFG area.

1996

USACE conducted a removal action along Prairie Creek at Site L3. 1996 Public Law 104-106 of Fiscal Year (FY) 1996 Department of Defense Authorization Act legislated specific terms for conveyance of JOAAP to various entitles.

1996

USACE performed interim operation and maintenance (O&M) activities at the southern ash pile at area M1.

1997

USACE conducted a removal action for organics and PCB contaminated soil at area L6.

1997

Separate FSs prepared for the GOU and SOU for both the LAP (Dames and Moore) and MFG areas. (OHM Remediation Services Corporation [OHM])

1997

Proposed Plan for SOU and Proposed Plan for GOU prepared by U.S. Army to provide rationale for proposed remedies.

1997

Proposed Plan for SOU and Proposed Plan for GOU presented at a public meeting.

January 1998

Pre-Design Investigation activities including soil and groundwater sampling at MFG and LAP areas by MWH Americas, Inc. (MWH).

1998

ROD for SOU and GOU at MFG and LAP Areas is submitted by U.S. Army

October 1998

Final Remedial Design (RD)/Remedial Action (RA) Work plan for SOU and GOU submitted by MWH to USEPA and IEPA.

April 1999

Interim O&M activities conducted at Site M1 with cap replacement April 28, 1999

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Event Date with an impermeable plastic liner. Start of construction for Site M4 Soil Stockpile Area. May 5, 1999 SOU and GOU Remedial Action Trigger (Start) Date. May 5, 1999 Groundwater samples collected from identified site wells in the MFG and LAP Areas according to the RD/RA Work plan.

June through November 1999

RA activities by MWH begin at MFG area Site M5. July 7, 1999 RA activities by MWH begin at MFG area Site M6. July 16, 1999 RA Activities at Site M5 to remove Soil Remediation Unit (SRU)1 and SRU3 contaminated soils.

July through November 1999

Semi-annual Groundwater Monitoring Report – Spring 1999 - submitted to USEPA and IEPA.

September 1999

Leachate collection and disposal activities begin at Site M9 as part of leachate control system O&M activities.

November 1999

Thirty-six monitoring wells abandoned in the MFG and LAP Areas. Abandonment reports were submitted in the Semi-Annual Groundwater Monitoring Report – Spring 2000.

December 1999, field activities. September 2000, reporting.

Ongoing soil bioremediation for explosives at Site M4. 1999 through 2004 Site M6 - Soil excavation has occurred intermittently at the Site; however, bioremediation, confirmatory sampling, and disposal performed almost continuously.

1999 through 2006

Annual Groundwater Monitoring Report – Fall 1999 -submitted to USEPA and IEPA.

January 2000

Groundwater samples collected from identified site wells in the MFG and LAP Areas according to the RD/RA Work plan.

May and October 2000

Semi-annual Groundwater Monitoring Report – Spring 2000 - submitted to USEPA and IEPA.

September 2000

Submittal of Final Closure Report – Site M5. December 2000 An enhanced temporary landfill cap installed at Site M9 Landfill to promote run-off.

2001

Annual Groundwater Monitoring Report – Fall 2000 -submitted to USEPA and IEPA.

March 2001

Twenty-six monitoring wells abandoned from the MFG Area. Documentation is provided in Semi-annual Groundwater Monitoring Report - Spring 2001.

March to May 2001, field activities. September 2001, reporting.

Groundwater samples collected from identified site wells in the MFG and LAP Areas according to the RD/RA Work plan.

May 2001, semi-annual event. October 2001, annual event.

Soil excavation for bioremediation treatment for explosives from Site M7.

July through October 2001

Semi-Annual Groundwater Monitoring Report – Spring 2001 - submitted to USEPA and IEPA.

September 2001

Eighteen monitoring wells installed to replace previously abandoned wells in the MFG and LAP Areas. Documentation is provided in the Annual Groundwater Monitoring Report - Fall 2001.

September and October 2001, field activities. April 2002, reporting.

Submittal of PCB Sites Final Closure Report. Sites L1, L7, L8, L9, L10 and L17.

December 2001

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Event Date Annual Groundwater Monitoring Report – Fall 2001 -submitted to USEPA and IEPA.

April 2002

Groundwater samples collected by MWH from site wells in the MFG and LAP Areas according to the RD/RA Work plan.

May 2002, semi-annual event. October 2002, annual event.

Soil excavation by MWH at Site M6 for bioremediation for explosives. July through November 2002 Ordnance and explosives removed from LAP Area Sites L11 and L16. August 2002 Three sumps and one concrete outflow removed from LAP Site L16. August 2002 Explosives contaminated soil excavated by MWH at LAP Site L16 for bioremediation review of groundwater results.

October 2002


November 2002

Arsenic contaminated soil excavated from LAP Area L11, confirmation samples collected, soil disposed of at Laraway Landfill in Elwood, Illinois.

October and November 2002

Approved explanation of Significant Difference (ESD) prepared by USACE for Site M1 to modify the Groundwater Management Zone (GMZ) boundaries, and submitted to USEPA and IEPA.

February 2003

Site M10 Final Closure Report submitted by MWH. March 2003 Annual Groundwater Monitoring Report – Fall 2002 -submitted to USEPA and IEPA.

March 2003

Groundwater samples collected by MWH from site wells in the MFG and LAP Areas according to the RD/RA Work plan.

May 2003, semi-annual event. October 2003, annual event


October 2003

Submittal of Final Closure Report Site M7. November 2003 Submittal of Final Closure Report Sites L11/L16. December 2003 Well abandonment and replacement activities at Site M13. Documentation included as Appendix D of Fall 2003 Groundwater Report.

January 2004, field activities Reporting – on-going

Submittal of Final Five-Year Review Report, Soils Operable Unit. April 2004 Bioremediation Post Treatment Sample Frequency Reduction of Site M6 SRU3 Soils, Bioremediation Facility.

April 2004

Submittal of the First Five Year Review for the SOU and GOU. May 6, 2004 ROD for Soil Operable Unit Interim Sites signed. June 2004 Submittal of Sampling and Analysis Plan, SB-1 Treatment System, Site M4 Bioremediation Treatment Facility.

June 2004

Submittal of Draft Final Treatment Completion Report, SRU1 Tetryl Soils, Revision 1.

June 2004

Submittal of Stormwater Basin (SB-1) Discharge Exceedance Event and Corrective Action Report, Site M4 - Bioremediation Treatment Facility.

September 2004

Stormwater Basin (SB-1) Corrective Action Plan, Site M4 - Bioremediation Treatment Facility.

October 2004

Annual Groundwater Monitoring Report – Fall 2003 submitted to December 2004

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Event Date USEPA and IEPA. Submittal of Final FY2002 Bioremediation Report, Soils Operable Unit.

January 2005

2004 Incentive Fee Treatment Quantities, Site M4 - Bioremediation Treatment Facility.

March 2005

Conducted remedial action activities at Site L14. July 2005 through August 2005

Conducted remedial action activities at Site L7. July 2005 through February 2006

Conducted remedial action activities at Site L10. August 2005 through September 2005

Final RD/Remedial Action Work Plan (RAWP), Site M9 - submitted by MKM Engineers, Inc. (MKM).

September 2005

Conducted remedial action activities at Site L8. September 2005 through February 2006

Final Phase 2 - RD/RA Work plan Submitted. October 2005 Conducted remedial action activities at Site L1. October 2005 through March

2006 Conducted remedial action activities at Site L9. October 2005 through June

2006 Final RD/RAWP, Site L4 - submitted by MKM. November 2005 Conducted remedial action activities at Site M9. November 2005 through

April 2006 Conducted remedial action activities at Site L4. December 2005 through

April 2006 Conducted remedial action activities at Site M2. March 2006 through July

2006 Final Remedial Action Work Plan, Site M1 - submitted by MKM. April 2006 Final Operation and Maintenance Plan Submitted by MKM. May 2006 Submittal of Final Closure Report, Site M6, Soils Operable Unit. June 2006 Conducted remedial action activities at Site M3. July 2006 through September

2007 Conducted remedial action activities at Site M11. July 2006 through December

2007 Final Remediation Action Work Plan Military Munitions Response Program (MMRP) Sites L2, L3, and L34 - submitted by MKM.

October 2006

Submittal of Final Closure Report - Revision I, Sites L1, L7, L8, L9, L10, L14, and M2.

October 2006

Conducted remedial action activities at Site M12. November 2006 through September 2007

Final Explosive Safety Submission Amendment MMRP Sites L2 and L3 Buffer Zones and Site L34.

January 2007

Conducted remedial action activities at Site L2. February 2007 through October 2007

Conducted remedial action activities at Site L23A. April 2007 through May 2007

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Event Date Conducted remedial action activities at Site L5. June 2007 through 2008 Final L4 Remedial Action Completion Report submitted by MKM. August 2007 Final M9 Remedial Action Completion Report submitted by MKM. September 2007 Final M11 Work Plan submitted by MKM. September 2007 Final Remedial Action M13 Work plan submitted by MKM. September 2007 Submittal of Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12.

March 2008

Draft M11 Remedy in Place Report Submitted by MKM. September 2008

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3.0 BACKGROUND Much of the background and historical information provided in this report was derived from the Installation Action Plan for JOAPP, the 1998 and 2004 RODs, the USEPA Comprehensive Environmental Response, Compensation, and Liability Information System Envirofacts Warehouse Website, and the previous Five-Year Review.

3.1 General Site Background This section provides a description of site characteristics and the threat posed to the public and environment at the time of the October 1998 and June 2004 RODs.

The following subsections give a summary of the site characteristics and historical operations of JOAAP. Descriptions of individual sites within JOAAP are included in Section 3.2.

3.1.1 Physical Characteristics JOAAP is a former U.S. Army munitions facility located on approximately 36 square miles (23,542 acres) of land in Will County, Illinois (Attachment 1). The site is located approximately three miles north of Wilmington, Illinois, a community of 5,134 residents.

3.1.2 Land and Resource Use Joliet Army Ammunition Plant was constructed during World War II for the purpose of manufacturing, loading, assembling, packing, and shipping of bombs, projectiles, fuses, and supplementary charges. The production output at JOAAP varied with the demand for munitions. Although the plant was used extensively during World War II, in 1945 all production of explosives was halted, the sulfuric acid and ammonium nitrate plants were leased out, and the remaining production facilities were put in layaway status. The installation was reactivated during the Korean War, and again during the Vietnam War. Production at the plant gradually decreased until it was stopped completely in 1977. Since then, various defense contractors under facility-use contracts have utilized some areas of the installation. In April 1993, JOAAP property was declared as excess by the Army and is now being maintained by a small staff under liquidation status. The facility is not capable of explosives production and is undergoing transfer of use to other agencies and organizations in accordance with Public Law (PL) 104-106.

This law, entitled the Illinois Land Conservation Act of 1995, PL 104-106, Div. B, Title 29012932, Feb 10, 1996, stated that the Army will transfer JOAAP land to various federal, local and state jurisdictions. As of September 2005, the Army has already transferred 17,726 acres to the United States Department of Agriculture/Forest Service (USDA/FS), for establishing the Midewin National Tallgrass Prairie (MNTP); 982 acres to the Department of Veterans Affairs to establish a Veterans Cemetery; 455 acres to Will County, Illinois to establish the Will County Landfill, and 2,650 acres to the State of Illinois to establish two industrial parks. Totals of approximately 19,100 acres will be transferred to the USDA/FS and 3,000 acres will be transferred to the State of Illinois. Section 4.1.1.8 provides additional details regarding property transfer activities.

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During the time when JOAAP was fully operational, it was divided into two main function areas: the LAP Area, located to the east of Route 53, and the MFG Area, located to the west of Route 53 (Attachment 2). The LAP Area, which covers approximately 22 square miles, is where munitions were loaded, assembled, and packaged for shipping. This area of JOAAP contained munitions, filling and assembly lines, storage areas, and a demilitarized area. The MFG Area, which covers approximately 14 square miles, is where the chemical constituents of munitions, propellants, and explosives were manufactured. The production facilities were located in the northern part of the MFG Area. On the southern half of the MFG Area there were extensive explosives storage facilities.

3.1.3 History of Contamination Past releases and disposal practices at JOAAP have resulted in soil and groundwater contamination with explosives compounds, metals, organics, PCBs, sulfur, and hazardous and non-hazardous debris. Due to the presence of contamination in both groundwater and soil at JOAAP, separate Operable Units (OUs) were established for each media to address remediation objectives at the site. In the Initial Record of Decision, Soil and Groundwater Operable Units, Manufacturing and Load-Assemble-Package Areas (U.S. Army, October 1998), a total of 26 SOU sites were identified as requiring additional remediation of contaminated soils and debris. Seven Soil Remediation Units (SRUs) were established to classify the 26 SOU sites according to the nature of contaminants:

� SRU1 – Explosives in Soil � SRU2 – Metals in Soil � SRU3 – Explosives and Metals in Soil � SRU4 – PCBs in Soil � SRU5 – Organics in Soil � SRU6 – Landfills � SRU7 – Sulfur

The 1998 ROD selected final remedies for all sites in the SOU contaminant groups of PCBs (SRU4), landfills (SRU6), and sulfur (SRU7), and for the sites contaminated with explosives (SRU1), metals (SRU2), intermixed explosives and metals (SRU3) and organics (SRU5) for JOAAP lands intended for transfer to the state of Illinois for the development of industrial parks. The 1998 ROD also selected interim remedial goals and remedies for SRUs 1, 2, 3, and 5 for the JOAAP lands intended for transfer to the USDA/FS for the development of the MNTP. Final Remedial Goals (RGs) and final remedies were developed for the interim portion of the 1998 ROD and presented in the second and Final ROD for the Soil Operable Unit Interim Sites (U.S. Army, June 2004).

Table 2 summarizes the Contaminants of Concern (COC) for each site based upon SRU designation. Due to the nature of activities conducted at many of the SOU sites, contaminants from more than one SRU may be present at any particular site.

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Table 2: Contaminants of Concern

SRU Description Final Remedial Action Sites Contaminants of Concern

1 Explosives M5, M6, M7, L16 (ROD-1998) L1, L2, L7, L8, L9, L10, L14, M2, M3 (ROD-2004)

Dinitrotoluene (DNT), Nitrotoluene (NT), Trinitrobenzene (TNB), Trinitrotoluene (TNT), High Melting Point Explosives (HMX), Royal Demolition Explosives (RDX), Tetryl

2 Metals L11 (ROD-1998) L2, L3, L5, L23A, M4, M12 (ROD-2004)

Arsenic, Beryllium, Cadmium, Copper, Lead

3 Explosives and Metals

M5, M6 (ROD-1998) L3 (ROD-2004)

DNT, TNT, RDX, Arsenic, Beryllium, Lead

4 PCBs L1, L5, L7, L8, L9, L10, L17 (ROD1998)

PCB1254, PCB1260

5 Organics L1, L5 (ROD-2004) Total Petroleum Hydrocarbons (TPH)/ Polynuclear Aromatic Hydrocarbons (PAHs)

6 Landfills M1, M9, M11, M13, L3, L4 (ROD-1998) Hazardous and Non-hazardous Wastes 7 Sulfur M8, M12 (ROD-1998) Sulfur

In addition, twenty-eight (28) other sites plus two subareas, suspected as having contaminated soil, were investigated during the Phase 1 and Phase 2 Remedial Investigation/Feasibility Study (RI/FS) and determined to have either no historical evidence suggesting contamination potential, no contamination, or contaminant concentrations that do not pose a threat to human health or the environment. Soils at these sites exhibit no characteristic of hazardous wastes. Illinois Environmental Protection Agency and USEPA agree that, under CERCLA requirements, no further cleanup actions are required for these sites, and have been classified as No Further Action (NFA) sites. Contaminant concentrations remaining at NFA sites (excluding Sites L6 and M16) are present at levels which allow for unlimited access and unrestricted use. Sites L6 and M16 have contaminant concentrations present at the sites which meet industrial RG designated in the October 1998 ROD.

A summary of initial responses at JOAAP, along with the general basis for taking actions at JOAAP, is presented in the following paragraphs.

Site-specific information describing the physical characteristics, source(s) and history of contamination, initial responses, and basis for taking action, is located in Section 3.2. The location of each individual site within the MFG and LAP areas is presented in Attachment 2.

3.1.4 Summary of Initial Response In 1978, the U.S. Army Environmental Center (USAEC, formerly the U.S. Army Toxic and Hazardous Materials Agency or USATHAMA) conducted an Installation Assessment of JOAAP (USATHAMA, 1978), which consisted of records search and interviews with employees. This document reported that environmental impacts might be present at former industrial areas and locations where waste disposal activities occurred.

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In 1981 and 1982, an Installation Restoration Survey was conducted (Donohue and Associates, 1982). This study included sampling of soils, groundwater, surface water, and sediment, and identified the presence of contamination at nine study areas at the MFG Area and nine study areas at the LAP Area.

Subsequently, a Phase II study was conducted in 1983 (Donohue and Associates, 1983) to gather additional data on the previously sampled sites at the MFG and LAP Areas, and to evaluate the potential for offsite impacts. This investigation also included an assessment of several parcels of land near the edge of the MFG Area that were considered part of excess inventory. No offsite contamination was identified.

From 1983 through 1985, a response action was conducted by Uniroyal (JOAAP’s operating contractor) at the Red Water lagoon located at Site M7. The purpose of this response action was to remove contaminated surface water and sediment from the lagoon. Following the removal of contaminated materials, a clay cap was installed over the lagoon. Pre- and post-remediation sampling documented the conditions before and after the remediation (Donohue and Associates, 1983, 1985).

Between 1983 and 1985, the U.S. Army Environmental Hygiene Agency (USAEHA) performed groundwater sampling of selected, existing monitoring wells. The sampling and monitoring were performed as part of JOAAP’s Resource Conservation & Recovery Act (RCRA) groundwater monitoring program around a closed sanitary landfill located at site M13, and the Red Water lagoon at site M7.

In November 1984, because of the presence of contamination, the MFG Area of JOAAP was proposed by the USEPA for listing on the NPL based on the Hazard Ranking System (HRS) score of 32.08. The LAP Area was proposed for listing in April 1985 based on the HRS score of 35.23. Final listing on the NPL took place on July 21, 1987 for the MFG Area, and March 31, 1989 for the LAP Area.

During 1985 and 1986, additional groundwater and surface water samples were collected from previously sampled locations at the MFG and LAP Areas. These data were presented in an assessment report in which the feasibility and the need for remediation of the study areas were discussed (Dames & Moore, 1986).

In 1989, the Army, the USEPA, and the IEPA entered into a FFA under CERCLA Section 120 and RCRA Sections 6001, 3008(h), 3004(u), and 3004(v) (USEPA, 1989). The purpose of this FFA was to ensure that environmental impacts at the site would be investigated and that remedial actions would be taken to protect public health, welfare, and the environment. Also during 1989, the USACE made an investigation of USTs throughout the JOAAP (USACE, 1989). One hundred and seven USTs were identified, inventoried, and evaluated for possible leakage, in accordance with USEPA regulations for existing USTs. Most of the USTs were emptied and removed as of 1993.

From 1988 through 1993, Phase 1 and Phase 2 RIs were conducted at the MFG Area (Dames & Moore, 1991, 1993). The RIs were performed to identify the type, concentration, and extent of

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contamination throughout the MFG Area. A total of 18 study areas were identified for investigation, including nine areas originally investigated during previous studies. These reports were amended by the Oleum Plant RI report (Dames & Moore, 1996) that was added as a potentially contaminated area following the completion of the RI reports.

From 1991 through 1994, Phase 1 and Phase 2 RIs were conducted at the LAP Area for the same purposes as the MFG Area investigations (Dames & Moore, 1993; 1994). A total of 35 study areas were investigated, including nine sites investigated during the Installation Restoration Surveys at the LAP Area.

The RI reports were supplemented by baseline risk assessments conducted to quantify the potential human health risks posed by contamination identified at the study sites present at the MFG and LAP Areas (Dames & Moore, 1994; 1995). The assessments included an environmental fate and transport assessment, a toxicity assessment, an exposure assessment, and a risk characterization.

From 1993 through 1996, the CHPPM conducted an ecological risk assessment to evaluate the potential for site contamination to be impacting ecological receptors. Findings indicated limited impacts to terrestrial mammals, aquatic receptors, and avian species (birds). The results of these studies were presented in a Phase 1 Ecological Risk Assessment Report (CHPPM, 1994) and a Phase 2 Aquatic Ecological Risk Assessment Report (CHPPM, 1996). Potential risks posed to humans from consuming deer tissue from JOAAP were also investigated and determined to be negligible (CHPPM, 1994).

Following the risk assessments, PRGs were established to identify the specific cleanup to remediate the sites (OHM, 1996). The cleanup levels were developed to be protective of human health and the environment.

In 1996 and 1997, the USACE conducted three removal actions to prevent the migration of contaminants from the source areas. Waste present in the oil pits located at study area L2 were excavated and disposed to prevent the contaminants from migrating into the groundwater. During the same time period, USACE, Omaha District conducted a Removal Action along Prairie Creek at site L3. This action involved stabilizing the stream bank to prevent erosion of the bank that contained buried debris and waste. Also in 1996, USACE conducted the removal of the PCB switch boxes from the MFG Area. Soils around the switch boxes were sampled and subsequently removed if contamination was above RGs or if staining was noticeable. In 1997, USACE conducted a Removal Action at Site L6. This action involved the excavation and disposal of organics- and PCB-contaminated soil to protect human health and the environment. This action also was intended to facilitate the transfer of the land from the Army to Will County, in accordance with Public Law 104-106 for establishing a landfill.

Public Law 104-106 of the FY 1996 Department of Defense Authorization Act legislated specific terms relating to the conveyance of JOAAP to various entities. This law is the governing document for the future land use at JOAAP. The majority of JOAAP is to be transferred to the USDA, with the U.S. Department of Veterans Affairs, Will County, and the State of Illinois receiving the remainder of the property.

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In 1997, an interim O&M activity was conducted at the southern ash pile (Site M1). This project involved consolidating waste that had migrated from the pile and covering the pile with a geosynthetic liner to prevent leaching of waste from the pile.

Interim O&M activities were conducted at Site M9 during 1999 to install a leachate control, recirculation and collection system. The leachate control system was implemented to prevent leachate seepage from the existing cap into the surrounding environment.

Since the volume of explosives-contaminated soil may have had a direct bearing on the selected remediation method, field screening soil sampling programs were conducted in 1995 to provide data to more accurately estimate the volume of explosives-contaminated soils on the MFG and LAP Areas. These programs were supplemented by sampling to help characterize the types of wastes present, and the results of the sampling programs were used in the FS for the MFG and LAP Areas. The purpose of the FS was to identify and evaluate alternative remedies for mitigating the risks posed by contamination at JOAAP. Separate FS were prepared for the Groundwater and Soil Operable Units for both the LAP (Dames & Moore, 1997) and MFG (OHM, 1997) Areas. Based on the information gathered and presented in the FS, the Army recommended, with USEPA and IEPA concurrence, the preferred remedies for the contaminated soil and groundwater at JOAAP. The rationale behind the selection of the remedies was released to the general public in the Proposed Plan for the Soil Operable Unit and the Proposed Plan for the Groundwater Operable Unit (U.S. Army, 1997 a, b), and presented at a public meeting on January 8, 1998.

The initial ROD was signed for JOAAP in November 1998. The 1998 ROD selected final remedies for the Groundwater Operable Unit and final remedies for the Soil Operable Unit contaminant groups of PCBs (SRU4), Landfills (SRU6), and Sulfur (SRU7). The 1998 ROD also selected final remedies for portions of the Soil Operable Unit contaminant groups of explosives (SRU1), metals (SRU2), intermixed explosives and metals (SRU3), and organics (SRU5) for JOAAP lands intended for transfer to the state of Illinois for the development of industrial parks. The 1998 ROD selected Interim remedies for SRUs 1, 2, 3, and 5 for JOAAP lands intended for transfer to the USDA/FS for the development of the MNTP pending the development of soil cleanup goals that would protect prairie workers and the environment.

A multi-agency management team was formed comprised of representatives from the Army, USEPA, IEPA, USDA/FS, US Fish and Wildlife Service (USFWS), and Illinois Department of Natural Resources (IDNR). This team tasked two sub-teams of human health and ecological risk assessment technical experts with developing preliminary remediation goals protective of the future MNTP lands. The technical work groups completed their assessment of available literature, databases, and site specific data and presented their findings in separate technical reports (Human Health Work Group, 2000; Ecological Work Group, 2000). The Management Team further refined the lists of chemicals of concern and developed an agreement document that defined the pre-sampling requirements for each site, the remediation goals that must be met by the average concentrations across the excavation areas, the excavation design values, confirmatory sampling, and the disposition of sewer lines.

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Alliant Techsystems, Inc., under a facility-use contract to the U.S. Army, used a portion of the LAP Area. Alliant ceased operations in 1999 and demobilized from the LAP Area in 2000.

Plexus Scientific Corporation was contracted by the U.S Army to conduct decontamination and demolition activities for buildings contaminated by historical activities in the LAP and MFG Areas. Decontamination and demolition activities were initiated in January 2000 by Plexus at Site M6. RA activities at Site M6 were considered complete following the final inspection by the USACE on July 25, 2005.

Using the data from the 1997 FS documents, an updated Focused Feasibility Study (FFS) was developed (2004, USACE) to present final cleanup values and evaluate alternatives for the interim ROD sites. A Proposed Plan document for the interim ROD sites was provided for public comment from February 20, 2004 to March 20, 2004 and was publicly presented on March 3, 2004. One comment of support was received from the Restoration Advisory Board (RAB) members (Section 14 of the June 2004 ROD).

3.1.5 General Basis for Taking Action The human health risk assessments identified a total of 79 COC in soil and sediment, 40 COC in groundwater, and 45 COC in surface water at JOAAP. Explosives (primarily TNT, DNT, RDX, HMX, and tetryl) were the most prevalent COC in each of these media, although other contaminants (metals, pesticides, PCBs, volatile organic compounds [VOCs], and semi-volatile organic compounds [SVOCs]) were also identified. Table 3 presents the prevalent soil and sediment explosive and groundwater explosive COC located at JOAAP.

Table 3: Prevalent Soil and Groundwater Explosive COC

Soil and Sediment Explosives Metals PCBs 2,4-DNT Arsenic Aroclor 1254 2,6- DNT Beryllium Aroclor 1260 TNB Cadmium TNT Lead RDX

HMX NT Groundwater Explosives Metals VOCs 2,4-DNT Iron Tetrachloroethene 2,6- DNT Antimony Toluene TNB Cadmium Benzene TNT RDX HMX

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According to Page 4-1, Paragraph 2 of the October 1998 ROD, although 45 COC were identified in surface water, Risk Assessment studies determined that surface waters at JOAAP pose no risk to human health and the environment, and were therefore not addressed as a contaminated medium requiring remedial action.

Based on information presented in the human health risk assessments, the principal threat to human health results from potential exposure to explosives in soil. DNT is identified by USEPA as a probable human carcinogen, and both TNT and RDX are identified by USEPA as possible human carcinogens. Risks and hazards calculated for groundwater are based on the assumption that new wells are installed into areas of contaminated groundwater and then used. This scenario is unlikely to occur because the majority of the contaminated groundwater resides in the glacial drift aquifer that does not provide usable quantities of groundwater and is not used as a source of water supply at JOAAP.

A Management Group composed of representatives of the Army, USEPA, IEPA, USDA/FS, IDNR, and Department of Interior/USFWS, was established to decide on the remedial goals for the land bound for the USDA.

Appropriate final remedial actions for future USDA soils have been developed, evaluated, selected, and presented in the Proposed Plan for the Soil Operable Unit, Interim ROD Sites (U.S. Army, February 2004). The selected remedies for interim sites were formerly presented and approved by the appropriate regulatory agencies in accordance with the NCP in the June 2004 ROD.

The primary objective of the cleanup at JOAAP was to effectively mitigate, minimize threats to, and provide adequate protection of human health and the environment. Human health risk models and other appropriate USEPA and IEPA criteria were used to establish the RGs for each of the COC identified in soils at JOAAP. Final RGs for soil were established for recreational land use (tall prairie grass, hiking, etc.) scenarios. Exposure levels for ecological resources that are protective of the environment and compatible with development of the tall grass prairie were determined for the USDA/FS lands and finalized in June 2004 ROD.

3.2 Site Specific Background Information This section provides a description of the individual sites of concern at JOAAP. Site-specific descriptions include the physical characteristics, land and resource use, history of contamination, initial responses, and basis for taking action at each site.

Table 4 summarizes the status of each site at JOAAP as a completed remedial action site (where the site has achieved closure status), or an incomplete remedial action site (where the site has not achieved closure status).

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Table 4: Summary of Site Remedial Action Status

Site SRU Completed Soil

Remedial Actions Closure Report

Final

Closure Report Submitted

Not Finalized

L1 SRU1, SRU4, SRU5 X X

L2 SRU1, SRU2 X X


L4 SRU6 X X


L7 SRU1, SRU4 X X L8 SRU1, SRU4 X X L9 SRU1, SRU4 X X

L10 SRU1, SRU4 X X L11 SRU2 X X L14 SRU1 X X L16 SRU1 X X L17 SRU4 X X

L23A SRU2 X X M1 SRU6 X X M2 SRU1 X X

M3 SRU1, SRU2, SRU3 X X

M4 SRU2 X X M5 SRU1, SRU3 X X M6 SRU1, SRU3 X X M7 SRU1 X X M8 SRU7 X X M9 SRU6 X X

M11 SRU6 X X M12 SRU2, SRU7 X X M13 SRU6 X X

3.2.1 Site L1 Site L1 was constructed in 1941 as part of the initial operations of the installation to support World War II efforts. This 80-acre site is centrally located in the northern portion of the LAP Area. Site L1 was the location of demilitarization and reclamation of various munitions. It was originally used for crystallizing ammonium nitrates, but then extensively modified to function as a shell renovation and 1,3,5-TNB recovery plant until 1945. In April 1946, the facility was reactivated to reclaim TNT. Washout operations involving the larger munitions were performed outside Building 61-35, which is located southeast of Building 61-4. The solids that settled in the sump were sent to Site L2 (Explosive Burning Grounds), while the overflow from the sump (pink water) was discharged to an adjacent 4.3-acre ridge-and-furrow system (or evaporating bed).

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Historical aerial photos revealed that by 1952 two rectangular pits or lagoons had been constructed southeast of the ridge-and-furrow system on either side of drainage ditch that flows south from the ridge-and-furrow system and empties into Prairie Creek.

3.2.1.1 Site L1 Soils in SRU1 The majority of the SRU1 contaminated soil was present in the ridge and furrow system. The Final Phase 1 RI Report, LAP Area, JOAAP, Joliet, Illinois (Dames & Moore, July 1993) detected 2,4,6-TNT in soil samples SC091 and SC093 at concentrations of 14,400 milligrams per kilograms (mg/kg) and 14,500 mg/kg, respectively. In addition, impacted soil was identified on the south side of the washout building and surrounding the sump. Site L1 contained an estimated 4,240 cubic yards (CY) of SRU1 soil above RGs as designated by the June 2004 ROD.

3.2.1.2 Site L1 Soils in SRU4 Two transformers removed in August 1990 from an area east of Building 61-4 were suspected to have leaked oil-containing PCBs onto site soil; the spill was subsequently remediated.

No RCRA hazardous wastes were identified at Site L1.

3.2.1.3 Site L1 Soils in SRU5 Sampling was performed near the aboveground storage tanks (ASTs) located next to Buildings 61-1 and 61-2 during the Waste Classification and Volume Estimates Plan (WCVEP) (Dames & Moore, 1995) investigation to evaluate potential contamination from spills, leaks, etc. of fuel formerly stored in these tanks. In the vicinity of the AST location west of Building 61-1, one soil core was collected at multiple depths and detected TPH in all samples at concentrations ranging from 4,020 mg/kg to 111,000 mg/kg, which exceeded the developed and agreed upon TPH RG of 2,500 mg/kg. The surface area contaminated by TPH was estimated to be 2,500 square feet (SF), and contamination was assumed to extend to a depth of 10 feet. The volume of soil considered for RA was estimated to be 925 CY in the June 2004 ROD near Building 61-1.

One surface soil sample was collected near the valves of the two ASTs located within an earthen berm north of Building 61-2 and analyzed for benzene, toluene, ethylbenzene, and xylenes (BTEX), PCBs, and Toxicity Characteristic Leaching Procedure (TCLP) organics. Based on these results, there were no BTEX or PCB constituents that exceeded RG criteria; however, based on visual observations during the WCVEP investigation, soil below the ASTs within the surrounding earthen berm was heavily saturated with petroleum products and was assumed to be contaminated with TPH above the cleanup level. The hydrocarbon-stained soil was limited to the area within the earthen berm surrounding the tanks, which was approximately 900 SF based on field measurements. Therefore, the volume of soil considered for RA north of Building 61-2 was estimated to be 350 CY in the June 2004 ROD, assuming contamination extended to a depth of approximately 10 feet below ground surface (bgs).

In summary, a total volume of 1,275 CY of SRU5 soil was estimated by the June 2004 ROD to be contaminated above the TPH RG at the two AST locations of Site L1.

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3.2.1.4 Summary of Site L1 Soil Site L1 is not located near a heavily populated area. The future land use of Site L1 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils and groundwater at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L1 was associated with SRU1, SRU4, and SRU5 soils. Final RGs and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.2 Site L2 (Explosive Burning Grounds) Site L2 is located in the west-central portion of the LAP Area, adjacent to Prairie Creek and Kemery Lake. The operational area for SRU1 soil covers approximately five acres and consists of six east-west burning pads, each approximately 650 feet long by 50 feet wide, on which explosives and associated wastes from other LAP area sites were burned. Three north-south burning pads were also present east of this area in 1952 aerial photographs. These pads were subsequently reconfigured into one pad, and the southern oil pits were constructed on the southern portion of these pads. Several parallel, elevated burning pads were constructed of gravel and fitted with electric igniters operated from a remote location. According to JOAAP personnel, spent carbon from the carbon units used in the TNT/Composition B melt-load processes was also incinerated on the burning pads. Munitions and Explosives of Concern (MEC), formerly called Unexploded Ordnance (UXO), including fuses and other items, have been identified to be present on the burning pads.

Three popping furnaces, where small ammunition was detonated, were located at the southwest corner of the site. During operations, metal waste from the furnaces was removed and sent to the Salvage Yard (Site L5). The Explosive Burning Grounds also contained three solvent and oil disposal pits (each less than 0.25 acre) located adjacent to the burning pads, which (according to JOAAP personnel) were occasionally used to burn waste oil. These pits were remediated in 1996 as part of a removal action conducted by the U.S. Army, and MEC were discovered to be buried in an area north of the burning pads. The MEC were disposed of properly as part of the removal action, although a complete MEC sweep was not performed and it is possible that additional MEC remain at the site in the vicinity of the removal action. Drainage features include two ditches, which flow from the northern portion of the burning pads to Kemery Lake, and a gully at the southwestern corner of the site, which receives runoff from the popping furnace area and southern portions of the site.

3.2.2.1 Site L2 Soils in SRU1 Analytical results of soil samples collected at Site L2 indicated that the majority of the burning pads area was contaminated with 2,4-DNT, 2,6-DNT, RDX The total volume of soil at this site that exceeded RGs for explosives was estimated to be 10,000 CY.

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3.2.2.2 Site L2 Soils in SRU2 Levels of arsenic, cadmium, and lead in soil surrounding the popping furnaces were shown to exceed the RGs. Surface soil contaminated with arsenic, cadmium, and lead has been estimated to extend to a depth of one foot bgs, representing a volume of 1,480 CY. Additionally, arsenic contamination in subsurface soils around the popping furnaces is estimated to occur to a depth of three feet bgs, representing a volume of 2,960 CY.

Soils in the vicinity of the popping furnaces at Site L2 are potentially contaminated with RCRA characteristic hazardous wastes for cadmium (RCRA waste code D006) and lead (RCRA waste code D008).

Based upon remedial investigation RI/FS data, an area in the southwest corner of the burning pads was identified with elevated concentrations of lead requiring excavation. Phase I RI sample AC102 (lead 500 mg/kg) and FS sample SS748 (lead 2,050 mg/kg) indicated lead concentrations above the RG designated in the June 2004 ROD.

In summary, 10,000 CY of SRU1 soils and 700 CY of SRU2 soils were estimated by the June 2004 ROD to be at Site L2.

3.2.2.3 Summary of Site L2 Soil Site L2 is not located near a heavily populated area. The future land use for Site L2 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils and groundwater at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L2 was associated with SRU1 and SRU2 soils, and potential MEC waste. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.3 Site L3 (Demolition Area) Site L3 is located directly southwest of the Explosive Burning Grounds (Site L2). Covering approximately 50 acres, Site L3 is bounded to the west by Prairie Creek, to the south by an unnamed tributary to Prairie Creek, and to the east by Star Grove Cemetery. The principal operation conducted in this area was the open burning of combustible refuse and munitions crates. An air curtain destructor, which facilitates combustion while reducing particulate emissions, was constructed at the site but never used. In addition, uncontaminated solid waste and some potentially low-level explosives-contaminated solid waste from JOAAP operations were burned in this area. A one-acre fire training area was also located at the site.

The burning area consisted of U- and L-shaped bermed areas and a burning cage, which is a concrete pad surrounded by a steel mesh cage used to contain the burning debris. During the Phase 1 RI, geophysical techniques used to clear MEC from work areas indicated the presence of buried metallic debris in and around the U- and L-shaped bermed areas. The fire training area consisted of a small depression enclosed by an earthen berm, which contained burning and fire

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training areas. The demolition pits (less than one acre) were heavily vegetated, which suggested there had been no recent activity in this area.

3.2.3.1 Site L3 Soils in SRU2 A total of 185 CY of soil was estimated to require a remedial action for lead. The volume of soil requiring remedial action at the fire training pit was assumed to include the top six inches of surface soil over the entire fire training area (approximately 75 by 125 feet) and totaled an estimated 175 CY. Soil in the area east of the demolition pits requiring remedial action was estimated to include a 25 SF area of surface soil to a depth of six inches, totaling 10 CY.

3.2.3.2 Site L3 Soils in SRU3 Results of sampling Site L3 indicated contamination of RDX and lead that exceeded RGs in the western portion of the bermed area with an approximate surface area of 170 SF from the western edge. Since samples from a depth of 2.5 feet did not exceed RGs for explosives or metals, soil contamination over the 170 square foot area has been assumed to extend one foot bgs. The volume of explosives and metals-contaminated soil within the bermed area of Site L3 was estimated to be 1,070 CY. In addition, MEC were identified in this area.

3.2.3.3 Site L3 Soils in SRU6 The berms located along Prairie Creek were contaminated with lead, chlordane, 2,6-DNT and phosphate above the RGs for these constituents. The berms are present within an area measuring approximately 800 feet along Prairie Creek and 300 feet wide in the northwest portion of Site L3. The entire area between Prairie Creek and the easternmost access road was presumed to be filled with metallic debris and other wastes including MEC.

The extent of contamination in the berms along Prairie Creek appeared to be related to the presence of fill material. Several assumptions were made to calculate fill volumes. Average berm heights were estimated to be eight feet in the northern berms and three feet in the southern berms. The average depth of fill was estimated at three feet bgs in the northern area and two feet bgs in the southern area. The fill was believed to be greater than 10 feet closer to Prairie Creek and pinches out east of the burning cage. The estimated volume of the material was 35,000 CY. Site L3 contained MEC, which are classified as RCRA characteristic wastes (RCRA waste code D003) because of their reactivity.

3.2.3.4 Summary of L3 Soils Site L3 is not located near a heavily populated area. The future land use for Site L3 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils and groundwater at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L3 was associated with SRU2, SRU3, SRU6 soils, and MEC waste.

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3.2.4 Site L4 (Landfill Area)

3.2.4.1 Site L4 Soils in SRU6 Site L4 is located southwest of the Demolition Area (Site L3), on the northern side of Prairie Creek. Two former extraction pits excavated to bedrock are located in this area. The western extraction pit was partially filled with construction waste and sanitary sewage, and the eastern pit has been flooded by Prairie Creek. Operating from the early 1940s (World War II) until the late 1960s, the landfill associated with the western pit reportedly accepted various types of construction debris. In addition, 5-gallon pails containing unknown substances were reportedly disposed of in the landfill. The final cover, reportedly compacted clean fill, was placed in the 1970s.

Neither site-specific contaminants nor RCRA hazardous waste were identified at Site L4. The boundaries of the Site L4 were delineated using data collected during the Phase 1 and Phase 2 RIs and the additional field investigation activities (Appendix A of RD/RA Work Plan [MWH, 1999a]). Based on the findings of these investigations, the waste in the Site L4 consisted of construction and demolition (C&D) debris to a maximum thickness of 12 feet. No fill was identified in the southwestern portion of the site, and the exposed bedrock in the southern area of the site defined the southern boundary of the landfill. Based on the extent of the Site L4 and its estimated depth, it was calculated that the landfill contained 37,000 CY of waste materials.

3.2.4.2 Summary of L4 Soils Site L4 is not located near a heavily populated area. The future land use for Site L4 is intended for development into the USDA MNTP. According to the baseline risk assessment, no media posed a risk to recreational user based receptors. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC.

3.2.5 Site L5 (Salvage Yard) Site L5 was used for salvage and open storage of miscellaneous materials from the installation. It is located in the northwestern corner of the LAP Area along Hoff Road. Metal waste from the popping furnaces at the Explosive Burning Grounds (Site L2) was reportedly sent to Site L5 when JOAAP was in operation. The area of contamination at the site included a 1,000-SF oil spill area near Building 26-3 and a 500-foot long shallow ditch excavated in 1974 that was located south of the spill area. This ditch was used to store barrels of unknown substance(s). Other areas of contamination included several large piles of railroad ties (approximately one acre), and a large junk pile (less than one acre).

3.2.5.1 Site L5 Soils in SRU2, SRU4, and SRU5 Metal contamination in the former open storage areas was primarily limited to surface soil. The concentration of lead in samples collected from the open storage area north of the junk pile exceeds the RGs. An estimated 1,070 CY of soil was considered for remedial action based on an

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affected surface area of 28,900 SF, and assuming contamination extended to a depth of one foot bgs.

In the former junk pile area, lead contamination exceeding the RG was primarily limited to surface soil with deeper hot spots located within the surface area. An estimated 1,965 CY of SRU2 soils required excavation from the junk pile area.

The 500-foot long shallow drainage ditch was an area at Site L5 that contained concentrations of metals (beryllium, lead, and arsenic) and organics (TPH) in soil at levels above the constituent-specific clean up levels for these constituents. The volume of contaminated soil in the ditch area was estimated to be 555 CY, assuming soils in an area 25 feet wide and 500 feet long were contaminated to a depth of one foot and, an area 25 feet by 50 feet contaminated to a depth of two feet.

The former oil spill area adjacent to Building 26-3 contained surface soils that exceeded the TPH RGs. The spill area was estimated to cover less than 1,000 SF. One soil core, SC591, was collected in the oil spill area during the PH1 RI (Dames & Moore, 1993). Samples were collected at 0-, 2.5-, and 5-feet bgs and were analyzed for explosives, anions, metals, VOCs, SVOCs, TPH, and PCBs/pesticides. During the Phase 2 RI (Dames &Moore, 1994), three soil cores (SC809, SC810, and SC8ll) were advanced around the perimeter of the oil spill to define the lateral extent of contamination. Samples were collected at 0- and 2.5-feet bgs and were analyzed for TPH, SVOCs, and metals. Additional surface soil samples were collected during the WCVEP investigation to refine the estimated volume of TPH-contaminated soil at the oil spill area (Dames & Moore, 1995). Eight surface soil samples (SS7l9 to SS724 and duplicate samples SS719D and SS723D) were collected around the former oil spill area and analyzed for TPH. The volume of TPH-contaminated soil in the oil spill area of Site L5 was estimated to be 30 CY and was limited to soils one foot bgs between Buildings 26-3 and 26-4.

The large piles of railroad ties were located over approximately one acre in the south-central section of Site L5. Soil samples collected within this area identified concentrations of benzo(a)pyrene above the RGs. Based on the available data, the extent of organics contamination above RGs was assumed to be limited to the western half of the area of the piles of railroad ties (an area of 300 feet by 100 feet) to a depth of 6 inches. This area represented a volume of approximately 550 CY.

The total volume of soil contaminated with organics at this site was estimated to be 1,135 CY. The contaminants of concern found at Site L5 also included arsenic, beryllium, lead, and benzo(a)pyrene. The maximum concentrations of these compounds exceeded the RGs levels.

No RCRA hazardous wastes were identified in the ditch and oil stained areas at Site L5.

RCRA hazardous wastes are potentially present in the area of the Junk Pile at Site L5 in the form of TCLP extractable lead (RCRA waste code D008) and TCLP extractable cadmium (RCRA waste code D006). The soils also contained PCBs, which are regulated as Toxic Substances Control Act (TSCA) hazardous substances. The source of the PCBs was suspected to be from a former transformer.

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No RCRA hazardous wastes were identified in the open storage area at Site L5.

3.2.5.2 Summary of L5 Soils Site L5 is not located near a heavily populated area. The future land use for Site L5 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L5 was associated with SRU2, SRU4 and SRU5 soils. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.6 Site L6 Site L6, a storage and service area, is in the southwestern portion of the LAP area. Miscellaneous buildings and structures at Site L6 included an electrical shop, a locomotive service building, carpenter shop, an AST, a motor pool, a laundry facility, and various equipment storage buildings. The locomotive service shop contained three repair pits and a 15-ton crane. An oil skimmer recovery system, which collected oil from the pits when JOAAP was in operation, was adjacent to the shop. According to JOAAP personnel, the spent oil was spread over local roads to minimize windblown dust. The electrical shop was used to repair and clean electrical equipment.

Historical aerial photo interpretation revealed that, in 1944, debris covered approximately eight acres in the southwestern portion of the site, south of the railroad tracks. The contents of the material previously stored in this area were unknown.

During a site investigation in March 1988, JOAAP personnel identified an area between the receiving building and electrical shop where oil from transformers, containing PCBs, had been dumped. In addition, waste solvents and oils generated from the electrical and machine shops had reportedly been dumped in the area. During a September 1987 site reconnaissance, a low lying area with ponded water and vegetative stress was identified between the locomotive service building and electrical shop.

Several other potential areas of concern were identified during a July 1990 site reconnaissance. JOAAP personnel indicated that PCBs may have been used to fireproof clothing in the receiving building. According to JOAAP personnel, painting and lacquering operations were performed at the western end of the carpenter’s shop. Paint thinner was reportedly dumped onto soils in this area.

During the Phase 1 RI field investigation, soil, groundwater, surface water, and sediment samples were collected. Soil samples were collected to evaluate the extent of contamination from past activities. Groundwater samples were collected to assess site conditions and monitor potential migration of contaminants. Surface water samples were collected to determine the impact of contaminated soil via surface runoff on the drainage ditch south of the machine shop.

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3.2.6.1 Summary of L6 Soils Based on the results of the Phase 1 RI, USACE conducted removal action at Site L6 in 1997 to remove organics and PCB-impacted soil that exceeded RGs. PCB contaminated soils were remediated to levels below 1.0 mg/kg, which was the standard for unrestricted use. Remaining COC at Site L6 that posed potential health and environmental hazards were removed to levels that met the industrial RGs set in the October 1998 ROD.

The removal action at Site L6 was documented in the Final Report, Removal Action Site L6/Group 70 Area, Joliet Army Ammunition Plant, Wilmington, Illinois (U.S. Department of Defense, March 1998). Based upon the results of the removal action activities, Site L6 was identified as a NFA site in the October 1998 ROD.

3.2.7 Site L7 Site L7 is located in the southern portion of the LAP Area. The basic processes and procedures involved in LAP operations are similar for all ammunition items. Explosives were melted and loaded into a projectile, and process water containing explosives residue was discharged to sumps. The loaded projectiles were then transferred to another building for final assembly. Solids collected in the sump were reportedly sent to the Explosive Burning Grounds (Site L2) for disposal. Liquids from the sump were discharged to a storm sewer, which ultimately discharged to Site L12 (Doyle Lake) from Sites L7, L8, and L10, or to Prairie Creek from Site L9. According to JOAAP personnel, carbon treatment units were installed in each melt-load building. Spent carbon units were disposed at the Explosive Burning Grounds.

3.2.7.1 Site L7 Soils in SRU1 Explosives contaminants in soil at Site L7 included 2,4,6-TNT, 1,3,5-TNB and RDX. Levels of explosives, up to 1.5 percent, were identified in soil from red-stained areas adjacent to buildings throughout the site. The total volume of affected soil for Site L7 was estimated by the June 2004 ROD to be approximately 925 CY.

3.2.7.2 Site L7 Soils in SRU4 Onsite PCB contamination resulted from leaks and spills associated with formerly used transformers. The transformers at Site L8 were properly removed during site liquidation activities.

3.2.7.3 Summary of L7 Soils Site L7 is not located near a heavily populated area. The future land use for Site L7 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L7 was associated with SRU1 and SRU4 soils. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

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3.2.8 Site L8 Site L8 is centrally located in the LAP Area, east of the intersection of Chicago and Central Roads. LAP operations performed at the site included melting and loading of Composition B into projectiles, subsequent cleaning and wash down operations that produced pink-water, and discharge of this waste water to external sumps and surface areas.

3.2.8.1 Site L8 Soils in SRU1 Explosives contaminants in soil at Site L8 included 2,4,6-TNT, and 2,4-DNT. During the RI/FS, high levels of explosives, up to 1.6 percent, were identified in soil from red-stained areas adjacent to buildings throughout the site. In addition, high levels of explosives were detected beneath washout Building 2-40B. Detectable concentrations of explosives occur in soils to a depth of five feet bgs. The total volume of affected soil, including areas beneath building foundations, was estimated to be approximately 400 CY by the June 2004 ROD. The volume of raw TNT was estimated to be one CY. Additionally, a total of 15 CY of structural concrete in the sumps is estimated for disposal.

The only RCRA hazardous waste identified at Site L8 was raw TNT, which is hazardous based on its reactivity (waste code D003).



3.2.9 Site L9 Site L9 is located in the central part of the LAP Area, one mile east of the intersection of Chicago and Central Roads. Operations were similar to those described for Sites L7 and L8.

3.2.9.1 Site L9 Soils in SRU1 Explosives contaminants of concern for soil at Site L9 included 1,3,5-TNB, RDX, and 2,4,6TNT. During the RI/FS, high levels of explosives, up to 4 percent, were identified in soil from red-stained areas adjacent to buildings throughout the site. High levels of RDX contamination occurred in a few locations beyond stained areas and were not as apparent as surrounding TNT

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contamination. The total volume of affected soil, including areas beneath building foundations, was estimated by the June 2004 ROD to be approximately 750 CY. The volume of raw TNT was estimated to be one CY. Additionally, a total of 15 CY of structural concrete in the sumps area was estimated for disposal.

The only RCRA hazardous waste identified at Site L9 was raw TNT which is hazardous based on its reactivity (waste code D003).



3.2.10 Site L10 Site L10 is located in the central part of the LAP Area, between Sites L7 and L8. Loadassemble-package operations performed at Site L10 were similar to those described for Site L7.

3.2.10.1 Site L10 Soils in SRU1 Explosives COC for soil at Site L10 included 2,4,6-TNT, 2,4-DNT, octahydro-1,3,5,7-tetranitro1,3,5,7-tetrazocine, HMX and RDX. During the RI/FS, high levels of explosives, up to 13.8 percent, were identified in surface soil from visually stained areas adjacent to buildings and sumps throughout the site. High concentrations of RDX occurred in some locations where staining was present and stressed vegetation was observed. Explosives were detected in heavily contaminated surface areas, beneath the foundation of one sump, Building 3A-53, Building 3A47, and next to the manhole near Building 3A-12. The total volume of SRU1 soil above RGs at Site L10 was estimated to be 1,200 CY by the June 2004 ROD.

The only RCRA hazardous waste identified at Site L10 was raw TNT, which is hazardous based on its reactivity (waste code D003).

3.2.10.2 Site L10 Soils in SRU4 Six transformers were also located onsite. Around 1987, one of the transformers in the northeastern part of the site reportedly leaked approximately four gallons of PCB-containing oil

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(with concentrations of 41,000 parts per million [ppm] PCB) onto a concrete pad. "Oil dry" was placed on the concrete to remove the oil, and the pad was wiped with a cloth soaked in a solvent containing VOCs.


3.2.11 Site L11 (Test Site)

3.2.11.1 Site L11 Soils in SRU2 Site L11, covering approximately 33 acres, is located immediately south of Group 1 (Site L7). This area was developed to test the firing velocities and impact effectiveness of various munitions within a secured perimeter fence. Munitions were fired within this area into a downrange target area consisting of a coarse gravel detonation pad constructed over native soil.

According to JOAAP personnel, during normal operations, approximately 10 ordnance items per month failed to explode. MEC clearance activities performed during the Phase 1 RI did not detect any MEC, although numerous fragments were detected.

Arsenic was found at a level above its RGs in all soil samples from the target area. The area affected by arsenic contamination, approximately 80 by 300 feet, was assumed to extend to a depth of six inches bgs. No RCRA hazardous wastes were identified at Site L11.

3.2.11.2 Summary of L11 Soils Site L11 is not located near a heavily populated area. The future land use for Site L11 is intended for development into the Island City Industrial Park. The development will include additional roadways for truck traffic and large areas reserved for warehouses. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to industrial users. Remediation goals presented in the October 1998 ROD were based upon risk-based models for industrial exposure of humans to COC. Within the SOU, the primary health threat at Site L11 was associated with SRU2 soils and MEC waste.

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3.2.12 Site L14

3.2.12.1 Site L14 Soils in SRU1 Site L14 is a 33-acre site located in the southwestern corner of the LAP Area, near Sites L15 through L19. It was initially constructed to produce various types of fuses. Mercury fulminate, reportedly stored at Site L14, was loaded into the fuses in the assembly line building (Building 414). After 1945, Building 4-14 was used for repackaging smokeless powder. According to JOAAP personnel, a sump north of Building 4-5 periodically overflowed resulting in soil contamination in this area.

Explosives COC included 2,4,6-TNT, HMX, and RDX. The highest concentrations of explosives (total concentrations of approximately 55,000 mg/kg) were detected in surface soil near the large sump north of Building 4-5. SRU1 soils above RGs were also detected in three soil piles located at the site. Explosive concentrations decreased with depth, but were detected in the deepest samples at the site, which were collected at five feet bgs. The total volume of SRU1 soil above RGs at Site L14 was estimated to be 420 CY in the June 2004 ROD.

An additional 20 CY of structural concrete in the sump area was estimated for disposal. No RCRA hazardous wastes were identified at Site L14.

3.2.12.2 Summary of L14 Soils Site L14 is not located near a heavily populated area. The future land use for Site L14 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils and groundwater at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L14 was associated with SRU1 soils. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.13 Site L16

3.2.13.1 Site L16 Soils in SRU1 Site L16 covers approximately 90 acres and is located in the southwestern corner of the LAP Area. Site L16 was initially constructed for the production of boosters for munitions. These sumps received wastewater during production activities at Buildings 6-2, 6-4, and 6-32, which then discharged into drainage ditches.

Explosives COC included HMX and RDX, which occurred at high levels in soil, primarily in a drainage ditch north of Building 6-32 and at the outfall of the sump. Other areas of explosives contamination occurred around the sump at Buildings 6-32, at entrances/exits to Building 6-2, and along the tile flume which extends west from the sump at Building 6-4.

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Final – Second Five-Year Review Report JOAAP – Soil Operating Unit

3.2.13.2 Summar y of L16 Soils Site L16 is not located near a heavily populated area. The future land use for Site L16 is intended for development into the Island City Industrial Park. The development will include additional roadways for truck traffic and large areas reserved for warehouses. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to industrial users. RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L16 was associated with SRU1 soils and MEC waste.

3.2.14 Site L17 (Group 7)

3.2.14.1 Site L17 Soils in SRU4 Site L17, a 90-acre site, is located in the southwestern corner of the LAP Area. It was initially constructed for the production of boosters for munitions. After termination of loading operations in 1945, Site L17 was used for repacking of lead azide. A sump was located at the southern end of Building 7-4, and a terra cotta flume drained to the west from the sump.

As identified for Site L17 (Group 7) in the October 1998 ROD, the north drainage ditch southwest of Building 7-6 contained PCB-contaminated soil and sediments.

3.2.14.2 Summary of L17 Soils Site L17 is not located near a heavily populated area. The future land use for Site L17 is intended for development into the Island City Industrial Park. The development will include additional roadways for truck traffic and large areas reserved for warehouses. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to industrial users. RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L17 was associated with SRU4 soils.

3.2.15 Site L23A (Disposal Pit)

3.2.15.1 Site L23A Soils in SRU2 Historic aerial photo-interpretation from 1946 identified a small (less than 0.5 acre) disposal pit located in the southwestern corner of Sites L23/L23A that is identified as Site L23A. It is not known what materials were placed in this pit; however, aerial photos from 1952 indicated that disposal activities had ceased.

Seven soil cores were advanced within and around the disposal pit at Site L23A. Lead was detected in soil samples from the pit at concentrations exceeding its RG. Lead-contaminated soil was assumed to extend across the center of the disposal pit and the area north of the pit (approximately 100 feet north-south by 150 feet east-west), to a depth of six feet bgs. The total

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affected volume of soil was estimated to be approximately 3,300 CY. No RCRA hazardous wastes were identified at Site L23A.

3.2.15.2 Summary of L23A Soils Site L23A is not located near a heavily populated area. The future land use for Site L23A is intended for development into the USDA MNTP. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site L23A was associated with SRU2 soils. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.16 Site M1 (Southern Ash Pile)

3.2.16.1 Site M1 Soils in SRU6 Site M1 is comprised of approximately 68 acres located in the southwestern part of the MFG Area. The Southern Ash Pile was used from 1965 through 1974 as a landfill for ash residues generated from the incineration of wastewater produced in the TNT manufacturing processes. The "red water ash" in the Southern Ash Pile was derived from K047-listed hazardous wastes.

The ash pile, measured 800 feet by 450 feet and covered approximately eight acres. The ash pile was 10 to 15 feet high and was estimated to contain 205,200 CY of material. Upon closure, the ash pile was originally covered with polyvinyl chloride (PVC) barriers, 12 inches of fill, and 6 inches of topsoil. However, as a result of erosion, the Southern Ash Pile was re-covered in 1985 with an additional 12 inches of clay and 6 inches of topsoil. Delineation of contamination at Site M1 was based on sampling and analysis performed in conjunction with the Phase II RI performed by Dames and Moore, Inc. in May1993. Due to continuing erosion, additional repairs to the ash pile cover were performed in 1993, and a temporary geosynthetic liner was installed in 1996 as part of O&M activities conducted by the U.S. Army.

IEPA notified the Army, by letter of July 24, 1998, that since the ash residues at M1 no longer exhibited the characteristic of reactivity (for which they were listed), they were not hazardous wastes regulated under 35 Illinois Administrative Code (IAC) 721.103(a)(2)(C). No RCRA hazardous waste was identified at Site M1.

3.2.16.2 Summary of M1 Soils Site M1 is not located near a heavily populated area. The future land use for Site M1 is intended for development into USDA MNTP. According to the baseline risk assessment, soils and groundwater at the site were stated to pose an unacceptable risk to recreational users. RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site M1 was associated with SRU6 soils.

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3.2.17 Site M2 (Explosive Burning Ground) Site M2 covers approximately 25 acres in the south central part of the MFG Area. Open burning of explosive wastes was performed on a four-acre burning pad until 1965. The burning pad consisted of gravel placed over the topsoil. Multiple areas of explosives-stained soil and absence of vegetation were visible in the northern portion of this site. Berms surrounded much of the burning pad area. A wetland area was present to the north of the burning pad area and along the eastern boundary of M2.

More than 400 tons of suspected "red water ash" were encapsulated in an impermeable membrane and buried at a shallow depth in the northern section of the explosives burning pad. The color, odor, texture, and apparent solubility of the buried waste were indicative of potentially untreated explosives sludge.

3.2.17.1 Site M2 Soils in SRU1 Explosives COC for soil at Site M2 included 1,3,5-TNB, 2,4,6-TNT, 2,4-DNT, and 2,6-DNT. The volume of explosives-stained soil at Site M2 exceeding the RGs was estimated to be 830 CY in the June 2004 ROD. The area of stressed vegetation at Site M2, without observable explosive residue, was estimated to represent an additional 500 CY of soil in the June 2004 ROD. Additionally, there was an estimated 270 CY of material in the "ash pillow." The total volume of SRU1 soil above RGs scheduled for excavation by the June 2004 ROD was approximately 1,600 CY.

Soils at Site M2 potentially include the following RCRA characteristic waste: soil contaminated with TCLP extractable 2,4-DNT (RCRA waste code).

3.2.17.2 Summary of M2 Soils Site M2 is not located near a heavily populated area. The future land use for Site M2 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site M2 was associated with SRU1. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.18 Site M3 (Flashing Grounds)

3.2.18.1 Site M3 Soils in SRU1, SRU2, and SRU3 Site M3 covers an area of approximately 66 acres located in the west central portion of the MFG Area adjacent to Grant Creek. From 1942 until 1988, the principal activity at Site M3 was the flash burning of equipment and demolition materials to remove explosives residues. The flash burning has been performed at two primary locations within a 6-acre fenced area. An area of

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explosives-stained soil, where trucks were washed after dumping explosives materials, was located between the primary burning pads and a dumping area/pad.

Four additional burning pads, located to the south of the fenced area of Site M3, were identified in aerial photographs. Each of these secondary burning pads in the central portion of Site M3 was estimated to be two acres. Numerous craters, located adjacent to the burning pads, were indicative of TNT block testing. Later photographs indicated that the area containing these southernmost burning pads had been covered with a layer of soil by 1953 but portions of the pads were still visible.

Explosives contaminants of concern for soil at Site M3 included 1,3,5-TNB, 2,4,6-TNT, and 2,4DNT. Based on the data collected at Site M3 and the non-intrusive nature of the flashing operation, the vertical extent of explosives contamination that exceeded the RGs was assumed to be limited to one foot bgs. ASTs were present at Site M3 during historical site activities. TPH-impacted soil may have been a result of incidental spills from the ASTs. TPH-impacted soils were most likely co-mingled with SRU1 impacted soils and were removed during RA activities to remediate SRU1 soils.

The total volume of explosives and TPH-impacted soil was estimated to be 400 CY. Approximately 150,000 of the 260,000 SF of topsoil within the six-acre fenced area of Site M3 were estimated to contain lead at concentrations above the RGs.

The vertical extent of lead contamination was assumed to be limited to one foot bgs based upon the non-intrusive nature of flashing operations. The volume of lead-contaminated soil in Site M3 exceeding the RGs was estimated to be 5,600 CY.

Explosives and lead contamination are commingled. The volume of SRU3 soils at Site M3 above RGs was estimated to be 2,000 CY.

Soils at Site M3 included the following RCRA characteristic wastes: TCLP-extractable 2,4-DNT (RCRA waste code D030) and TCLP- extractable lead (RCRA waste code D008).

3.2.18.2 Summary of M3 Soils Site M3 is not located near a heavily populated area. The future land use for Site M3 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site M3 was associated with SRU1 and SRU2 soils. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

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August 2009 W912QR-08D-0009/0002


3.2.19 Site M4 (Lead Azide Area)

3.2.19.1 Site M4 Soils in SRU2 Site M4 (Lead Azide Area) is located in the west central part of the MFG Area and covers approximately 136 acres. Lead azide, a primary initiating explosive, was produced at Site M4 from the early 1940s through the Korean War, and again during the Vietnam War from 1966 into early 1968.

The principal feature located in the western part at Site M4 was the Lead Azide Lagoon. The Lead Azide Lagoon was used as a settling basin to store wastewater treatment sludge from the manufacturing and formulation of lead-based initiating compound prior to neutralization and subsequent discharge to Grant Creek. Any remaining lagoon sludge was classified as K046 hazardous waste.

The Lead Azide Lagoon covered an area of approximately 2,000 SF. In 1982, the production facility in the central portion of M4 was demolished with the wreckage being burned within the Lead Azide Lagoon.

Lead in excess of RGs was detected in 14 of 20 soil samples analyzed from Site M4. Lead was detected in an area covering approximately 47,500 SF, and extending to a depth of three feet bgs. The volume of lead-contaminated SRU2 soil at Site M4 exceeding the RGs was estimated to be 4,200 CY.

Soils at Site M4 potentially contain RCRA characteristic hazardous wastes for TCLP extractable lead (RCRA waste code D008) and RCRA listed hazardous wastes for lead wastewater treatment sludges (RCRA waste code K046). The ditch leading away from the lagoon towards Grant Creek also showed lead concentrations.

3.2.19.2 Summary of M4 Soils Site M4 is not located near a heavily populated area. The future land use for Site M4 is intended for development into the USDA MNTP. According to the baseline risk assessment, soils at the site were stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site M4 was associated with SRU2 soils. Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD.

3.2.20 Site M5 (Tetryl Production Area)

3.2.20.1 Site M5 Soils in SRU1 and SRU3 Site M5 consisted of approximately 244 acres located in the central portion of the MFG Area. The principal activity at Site M5 during periods of operation was the production of tetryl. Tetryl

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was manufactured during World War II, the Korean War, and again during the Vietnam War until 1973. The Tetryl Ditch (oriented from north to south) bisected Site M5 with Production Lines 1 through 6 located west of the ditch and Productions Lines 7 through 12 constructed to the east of the ditch. Lines 1-6 were burned and removed. The Nitrating ("East-West") Ditch was located immediately to the north of the nitrating buildings in the tetryl production lines.

Each of the 12 tetryl production lines consisted of four separate "houses," oriented north to south, for nitrating, refining, wet storage ("lag-house") and drying. Wastewater from the tetryl manufacturing processes in the nitrating and refining houses flowed into settling boxes located on the west side of the buildings. Wastewater from the nitrating building was discharged into open drainage ditches that flowed to the north and into the Nitrating Ditch. The Nitrating Ditch drained into the Tetryl Ditch that ultimately drained into Grant Creek to the south of the Tetryl Production Area. Tetryl was visible within the settling boxes at the refining houses.

Wastewater from acid spills and daily floor cleaning was discharged from floor drains directly to the settling boxes at the nitrating and refining houses. Additionally, dust traps were constructed outside of the eastern doors of these buildings to collect tetryl residues.

The primary wastewater from the tetryl drying process was discharged to a settling box constructed immediately to the west of each drying house. Tetryl was visible within these settling boxes for Production Lines 7 through 12. A concrete weir was constructed in the Nitrating Ditch that formed a settling basin to the south of the acid recovery building for Tetryl Production Lines 7 through 12. Crystalline explosives compounds were visible in the basin sediment where the wastewater from the Acid Fume Recovery (AFR) building and the nitrating buildings on Production Lines 10, 11, and 12 collected.

Explosives contaminants of concern for soil at Site M5 included 1,3,5-TNB, 2,4,6-TNT, 2,4DNT, tetryl, and 2,6-DNT. Results of sampling of Site M5 indicated contamination of Tetryl, 2,4,6-TNT, 2,4-DNT, 2,6-DNT, lead and beryllium in excess of compound-specific RGs. Buildings in Site M5 West were removed in 1988, and the area was backfilled, regraded, and revegetated. Buildings in the Site M5 East Area were demolished in 1998 in conjunction with the liquidation activities at JOAAP. Unlike Site M5 West, the concrete floor slabs and footings within the Site M5 East Area remained in place prior to MWH’s 1999 summer field activities. Also, various building debris components were left on site in and near these building features.

3.2.20.2 Summary of M5 Soils Site M5 is not located near a heavily populated area. The site is currently owned by CenterPoint Properties, a private entity, and has been developed into an intermodal rail system. The development includes a rail spur, additional roadways for truck traffic, and large areas reserved for warehouses.

According to the baseline risk assessment, soils and sediment at the site were stated to pose an unacceptable risk to industrial users. Remediation goals presented in the October 1998 ROD were based upon risk-based models for industrial exposure of humans to COC. Within the SOU, the primary health threat at Site M5 was associated with SRU1 and SRU3 soils.

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3.2.21

D-0009/0002

Site M6 (TNT Ditch Complex)


3.2.21.1 Site M6 Soils in SRU1 and SRU3 Site M6 covers approximately 271 acres, located in the central part of the MFG Area. During World War II, the production of TNT and DNT were the major activities at Site M6. The TNT production lines were again operated at full capacity for the Korean and Vietnam Wars. During each of the inter-war periods, the plant mission was changed to a research and development (R&D) role in which explosive compounds, such as nitroxylenes, were produced. TNT production ceased in 1977.

Twelve parallel TNT “batch” production lines were initially constructed in the TNT Ditch Complex from south to north, with a total production capacity of 32,000,000 pounds of TNT per month. The principal buildings in each TNT production line were oriented east to west. The batch production lines were constructed in pairs; each line began with a “mono-house,” then a “bi-house,” followed by a “tri-house” for the nitration of toluene.

An AFR building (sometimes referred to as an AFR house) was located to the south of each bihouse. A “wash house” was located to the west of each tri-house. Process piping connected each of the nitrating buildings, the AFR building, and the wash house. Each pair of production lines shared a “nail house,” which was connected by a conveyor line to the wash house. Materials were loaded onto trucks and transported via the roadway to the north of each nail house. The explosives impacted soils identified at each nail house location was likely a result of incidental spillage during unloading of material from conveyors, and during loading operations onto the trucks.

Crude TNT was manufactured in a three-step process by the successive chemical addition of nitric acid to the toluene base product, using sulfuric acid as a catalyst. The initial nitration was performed in the mono-house with weak nitric acid to produce “mono-oil” (2-Nitrotoluene [NT]). The NT “mono-oil” was then pumped to the bi-house for the second nitration using additional oleum, a mixture of sulfuric acid and sulfur trioxide, and recycled nitric acid, resulting in “bi-oil” (primarily 2,4-DNT). The DNT “bi-oil” was then pumped to the tri-house. Each trihouse contained two “nitrator” tanks in which “bi-oil” was combined with oleum and a mix of nitric and sulfuric acids to produce “tri-oil” (2,4,6-TNT). The crude TNT was transferred to the wash house for neutralization with sodium carbonate (soda ash) and purification using sodium sulfite (sellite). The crystallized TNT was then dried, washed, and flaked prior to being packaged in boxes. A conveyor finally transferred the boxed TNT to the nail house where the containers were sealed.

Six DNT production lines, with DNT as the final product, were constructed between the paired TNT production lines. At each DNT production line, the “mono” and “bi” nitration steps were performed in a combined nitrating building. DNT purification was performed in a “sweatingand-graining” building located to the west of the DNT nitrating building. Total capacity for DNT production was 7,200,000 pounds per month.

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The TNT process wastewater from each tri-house and wash house, known as “red-water,” was initially discharged from wooden holding tanks to open clay-lined ditches that drained into the 9,100-foot-long “TNT Ditch.” The original wastewater drainage system, specific to the wash houses, was replaced in 1965 by a system of wooden flumes constructed in the TNT Ditch. The wash house red water was then diverted to the Red Water Area for treatment. The Red Water Area, Site M7, was constructed at the southern end of the TNT Ditch Complex.

Along the northern section of TNT Ditch, bedrock is typically encountered at a depth of 2.5 feet; however, in the eastern portion of Site M6, bedrock was encountered at a maximum depth of 35 feet during the installation of groundwater monitoring wells.

DNT-contaminated wastewater from the bi-houses and DNT sweating-and-graining buildings was discharged via wooden settling tanks into open troughs and ditches that flowed directly into the storm water sewer system and discharged into the TNT Ditch. Wastewater discharged directly to the TNT Ditch was not treated in the Red Water Area and flowed directly into Grant Creek.

In 1974, batch lines 11 and 12, at the north end of Site M6, were demolished, and three continuous operation TNT production lines were constructed in their place. The remaining buildings within the Site M6 batch-line area (Lines 1 through 10) were demolished in conjunction with the liquidation activities at JOAAP in 1998. The concrete floor slabs and footings remained intact, while the building debris was largely deposited near the original structures.

Occasionally, operational problems developed during the nitrating processes. To avoid potential explosion hazards, the explosives batch in progress could be flooded in water stored in large wooden “drowning” tubs. During the period from March 16, 1972 through September 14, 1974, there were more than 30 recorded instances in which batches of explosives were drowned. The batch drownings primarily occurred at the tri-houses during the final nitration step.

Approximately 4,800 pounds of DNT “bi-oil,” 5,600 pounds of Oleum (fuming sulfuric acid), and 2,800 pounds of nitric acid were released to the TNT Ditch with each event. Similar drowning tubs were located at each bi-house.

Explosives contaminants of concern for soil at Site M6 included 1,3,5-TNB, 2,4,6-TNT, 2,4DNT, 2,6-DNT, 2-NT, and RDX. The areas of contamination exceeding clean up levels included soils adjacent to each of the TNT wash houses, bi-houses, tri-houses, between the wash houses and the TNT Ditch, at the AFR Buildings, and around the perimeter of the laboratory building.

Results of sampling of Site M6 indicated that 2,4,6-TNT, 2,4-DNT, lead, arsenic, and beryllium exceeded compound-specific RGs. The volume of explosives (SRU1) and explosives and metals-contaminated (SRU3) soil in the TNT Ditch was 12,000 CY.

Soils at M6 included the following RCRA characteristic wastes: soils contaminated with TCLP extractable 2,4-DNT (RCRA waste code D030) and soils contaminated with TCLP extractable lead (RCRA waste code D008). The soils at M6 also contained RCRA-listed wastes if

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contaminated with red water (RCRA waste code K047) and DNT production waste waters (RCRA waste code K111).

3.2.21.2 Summary of M6 Soils Site M6 is not located near a heavily populated area. Site M6 will be transferred to the State of Illinois for inclusion into an industrial park. Developments within the industrial park are to include an intermodal rail system with a rail spur, additional roadways for truck traffic, large areas reserved for warehouses, and a coal-powered power plant. According to the baseline risk assessment, soils, sediment, and groundwater at the site were stated to pose an unacceptable risk to industrial users. RGs presented in the October 1998 ROD were based upon risk-based models for industrial exposure of humans to COC. Within the SOU, the primary health threat at Site M6 was associated with SRU1 and SRU3 soils. According to Page 4-1, Paragraph 2 of the October 1998 ROD, Risk Assessment studies determined that surface waters at JOAAP posed no risk to human health and the environment, and were therefore not addressed as a contaminated medium.

3.2.22 Site M7 (Red River Area)

3.2.22.1 Site M7 Soils in SRU1 Site M7 covers approximately 49 acres located in the central part of the MFG Area immediately to the south of the TNT Ditch Complex. The TNT Ditch formed the eastern boundary of Site M7. Facilities within Site M7 included three separate groups of storage tanks, pumping stations, evaporators, and incinerators. Beginning in 1965, these facilities were used to treat wastewater (red water) containing explosives residues and derivatives produced in the TNT manufacturing process. At that time, red water from the TNT wash houses was diverted from the TNT Ditch into wooden flumes. The red water was collected in storage tanks to the south of the TNT Ditch Complex. Overflow of untreated red water was stored in the Red Water Lagoon, located in the northern portion of Site M7. This 3.3-acre lagoon, with a capacity of 4.1 million gallons, was remediated in 1985.

Explosives contaminants of concern for soil at Site M7 included 1,3,5-TNB, 2,4,6-TNT, 2,4DNT, RDX, and 2,6-DNT. Soils at the M7 site were considered listed wastes if contaminated with red water (RCRA waste code K047) and DNT production waste water (RCRA waste code K111).

3.2.22.2 Summary of M7 Soils Site M7 is not located near a heavily populated area. Site M7 will be transferred to the State of Illinois for inclusion into an industrial park. Developments within the industrial park are to include an intermodal rail system with a rail spur, additional roadways for truck traffic, large areas reserved for warehouses, and a coal-powered power plant. According to the baseline risk assessment, soils, sediment, and groundwater at the site were stated to pose an unacceptable risk to industrial users. RGs presented in the October 1998 ROD were based upon risk-based models for industrial exposure of humans to COC. Within the SOU, the primary health threat at Site M7 was associated with SRU1 soils. According to Page 4-1, Paragraph 2 of the October 1998 ROD,

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Risk Assessment studies determined that surface waters at JOAAP posed no risk to human health and the environment, and were therefore not addressed as a contaminated medium.

3.2.23 Site M8 (Acid Manufacturing Area)

3.2.23.1 Site M8 Soils in SRU7 Site M8 covers an area of approximately 304 acres in the central portion of the MFG Area. The shape of M8 is an inverted "L" oriented lengthwise from north to south. Site M8 contained four areas in which nitric and sulfuric acids were produced and combined into various strength "mixes" for use in the manufacturing of DNT, TNT, and tetryl.

Acid Area 3 was located in the northeast corner of Site M8. The production of Oleum (fuming sulfuric acid), strong nitric acid, and other acids used in the production of explosives was the principal activity in Acid Area 3, which contained the Oleum Plant, the Northern Ammonia Oxidation Plant (AOP), and the Northern Acid Area.

The Oleum Plant was located in the northern portion of Acid Area 3. The southern half of the Oleum Plant consisted of concrete and brick pads for the receiving and storage of bulk sulfur. Raw sulfur was readily apparent throughout this area and along the southern railroad spur. No RCRA hazardous wastes were identified at Site M8.

During liquidation activities at the site, prior to the transfer of property to the State of Illinois, removal activities were conducted to remove sulfur from surficial soils. On August 10, 2000, the site was transferred to the State of Illinois. Following the land transfer, the State of Illinois sold the site to CenterPoint Properties. Subsequent site activities included the construction of an intermodal rail facility currently operated by Burlington Northern Santa Fe (BNSF). According to the Finding of Suitability to Transfer (FOST), February 1999, prepared by MWH on behalf of USACE, there were no exceedences of soil industrial remediation goals in all of Site M8.

3.2.23.2 Summary of M8 Soils Site M8 is not located near a heavily populated area. The current land use includes an intermodal rail system which includes a rail spur, roadways for truck traffic and large areas reserved for warehouses. Sulfur is not a CERCLA regulated waste, and was not identified in the October 1998 ROD as a risk to industrial receptors in any media at the site.

3.2.24 Site M9 (Northern Ash Pile)

3.2.24.1 Site M9 Soils in SRU6 Site M9 is comprised of approximately 20 acres located at the top of an escarpment in the north-central part of the MFG Area. The Northern Ash Pile was constructed during 1966 and 1967 as a landfill for ash residues from the incineration of TNT manufacturing wastes. The red water ash in the Northern Ash Pile is derived from K047-listed hazardous wastes. IEPA notified the Army,

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by letter of July 24, 1998, that since the ash residues at M9 no longer exhibited the characteristic of reactivity (for which they were listed), they were not hazardous wastes regulated under at 35 IAC 721.103(a)(2)(C).

Historical activities at the JOAAP resulted in the contamination of soil and groundwater, and the MFG Area of the JOAAP was listed as a National Priorities List (NPL) site on July 21, 1987. The LAP Area of JOAAP was listed as an NPL site on March 31, 1989. Phase 1 and Phase 2 RIs were performed at the two sites and the RI findings were used in the FS for both the MFG and LAP areas. The FS were used to develop the ROD and to document the final and interim remedies for remediation of the SOU. The M9 Northern Ash Pile was addressed in the 1998 ROD. The ash pile measured more than 625 feet by 600 feet and covered approximately five acres. The ash pile was 10 to 15 feet high with a domed top and steep sides. The Northern Ash Pile was estimated to contain 124,000 CY of material. Upon closure, the ash pile was originally covered with PVC barriers, 12 inches of fill, and 6 inches of topsoil; however, as a result of erosion, the Northern Ash Pile was recapped in 1985 with an additional 12 inches of clay and 6 inches of topsoil. Evidence of leaching from the eastern, southern and western edges of the Northern Ash Pile was observed during site reconnaissance in the form of stressed vegetation. The presence of several collapsed features across the ash pile were documented, some of which breached the clay cap and exposed ash material. The cap was repaired again by the U.S. Army in 1993. No RCRA hazardous waste was identified at Site M9.

During routine inspections of the cap, a leachate seep from the south side of the Northern Ash Pile was stressing vegetation and staining soils in the drainage channel south of the ash pile. The IEPA requested that interim measures be conducted to prevent the continued leachate seepage until permanent closure activities could be initiated.

MWH conducted test excavations at Site M9 in August 1998 to assess the leachate elevations and the depths of cover at the site. Results of this investigation indicated that the leachate appeared to be generated from surface water infiltration percolating through the existing earthen and plastic cover system on the ash pile. Infiltration water coming into contact with the ash material was found to be migrating laterally along the ash material. It did not appear that the leachate was percolating through the ash mass. Therefore, it was proposed to install a collection system that intercepted the leachate near the location of the leachate seep, at the interface of the cover system and the ash material.

A conceptual design memorandum for the Site M9 Interim Leachate System was prepared by MWH for submittal to IEPA, USEPA Region 5, USACE, and Army Industrial Operations Command (IOC) on October 28, 1998. Comments related to the conceptual design were received during a November 12, 1998 meeting among IEPA, USEPA, USACE, IOC, and MWH team members. It was established at that meeting that the conceptual design for Site M9 was satisfactory and that implementation activities for the project could proceed. MWH prepared and submitted a Work Plan for the interim leachate system for Site M9 dated December 23, 1999.

Interim O&M activities were performed at Site M9 from March 31 to May 10, 1999 and included installation of a leachate collection trench, which was installed within the ash pile;

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installation of a conveyance pipe to transport collected leachate to a central wet well; installation of a pumping system to pump leachate to a higher elevation in the ash pile; installation of an infiltration trench to recirculate leachate into the ash pile at higher elevations in the ash pile; and installation of a power source.

Greater than anticipated leachate volume generation within the Northern Ash Pile, prompted MWH to conduct additional interim site activities during July and August 2001. An additional three to four feet of treated soil from Site M4 was spread and compacted over the existing ash pile surface. The additional soil capping activities resulted in a noted reduction in leachate volume generation and disposal costs.

3.2.24.2 Summary of M9 Soils Site M9 is not located near a heavily populated area. Site M9 will be transferred to the State of Illinois for inclusion into an industrial park. Developments within the industrial park are to include an intermodal rail system with a rail spur, additional roadways for truck traffic, large areas reserved for warehouses, and a coal-powered power plant. Within the SOU, the media of concern at Site M9 is associated with SRU6 soils. According to the baseline risk assessment, the media at Site M9 were not identified as a risk to industrial receptors.

3.2.25 Site M11 (Landfill)

3.2.25.1 Site M11 Soils in SRU6 Site M11 is located to the east and south of the Explosive Burning Ground (Site M2) and covers approximately 133 acres. While initially used as a source of gravel, this area was operated between 1952 and 1978 as an uncontrolled dump. Site M11 was divided into two sections by School House Road. The Landfill was located on a ridge estimated to be 800 feet wide by 5,600 feet long and oriented northeast to southwest. The ridge rose 10 to 15 feet above the surrounding low plain.

A variety of waste materials were contained in the landfill. The materials included asbestos, insulation, and construction rubble. Numerous 55-gallon drums have also been identified; other debris included creosote-treated wood, paint cans and scrap metal. Similar materials are believed to be buried in the Site M11 gravel pit excavations. An area covered with asphalt tar was located in the central part of the southern portion of Site M11. A gravel pile, covered with a white residue, was also present in this part of the Landfill. Samples of the waste detected concentrations of lead at levels exceeding the TCLP limits, indicating that some of the wastes present would be classified as RCRA hazardous wastes. The estimated volume of the material was 66,600 CY. RCRA characteristic hazardous wastes are potentially present at Site M11 in the form of TCLP-extractable lead (RCRA waste code D008).

3.2.25.2 Summary of M11 Soils Site M11 is not located near a heavily populated area. The future land use for Site M11 is intended for development into the USDA MNTP. Within the SOU, the primary health threat at

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Site M11 was associated with SRU6 soils. According to the baseline risk assessment, the media at Site M11 were not identified as a risk to recreational user receptors.

3.2.26 Site M12 (Sellite Manufacturing Area)

3.2.26.1 Site M12 Soils in SRU7 Site M12 is located to the west of the TNT Ditch Complex in the northwestern portion of the MFG Area. Sellite was manufactured for use in the purification of crude TNT. Sellite consists of a solution of sodium sulfite and sodium sulfate. M12 included two sellite production units, a wastewater lagoon, and associated drainage ditches.

No data were collected that directly identifies the vertical extent of lead contamination at Site M12. Based on patterns of lead concentrations in samples collected in other areas within the MFG Area, lead contamination in soils and sediments at the Sellite Manufacturing Area was presumed to be limited to a depth of 12 inches bgs. The depth of contamination was based on high concentrations of sulfate throughout Site M12 and the insolubility of lead sulfate and other lead salts. The volume of lead-contaminated soil and sediment at Site M12 exceeding the RGs was estimated by the June 2004 ROD to be 3,200 CY and included both sediment in the lagoon and soils in the ditches.

The environmental impacts of raw sulfur on vegetation were observed at the wastewater outfall located to the north of the sellite manufacturing facility. The absence of vegetation in and immediately adjacent to surface deposits of sulfur was also noted in the former lagoon located in the northeastern portion of Site M12. The volume of sulfate-contaminated soil was estimated to be 1,400 CY. Soils at Site M12 may contain RCRA characteristic hazardous wastes for TCLP extractable lead (RCRA waste code D008).

3.2.26.2 Summary of M12 Soils Site M12 is not located near a heavily populated area. The future land use for Site M12 is intended for development into the USDA MNTP. According to the baseline risk assessment, sediment at the site was stated to pose an unacceptable risk to recreational users. Interim RGs presented in the October 1998 ROD were based upon risk-based models for recreational exposure of humans to COC. Within the SOU, the primary health threat at Site M12 was associated with SRU7 soils. Remedial action activities will be conducted at Site M12 to excavate and dispose of the SRU7 soils of concern at the site.

Final remedial goals and final remedies for the interim portion of the 1998 ROD were presented in the 2004 ROD. Following RA activities, soil and sediment containing COC above RGs were removed, thereby minimizing the risk to human health and the environment.

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3.2.27 Site M13 (Gravel Pit)

3.2.27.1 Site M13 Soils in SRU6 Site M13 is located in the central portion of the MFG Area to the north of the Tetryl Production Area, to the east of the TNT Ditch Complex, and to the west of Acid Area 1. The Gravel Pits cover approximately 106 acres.

Four potential disposal areas were identified within Site M13. Each of the disposal areas in Site M13 was less than 12 acres. Plant records and aerial photographs indicate that landfill activities at the Northern Gravel Pit began in 1966 and ceased in 1984. The topography in the vicinity of the Northern Gravel Pit is flat. The Northern Gravel Pit contained scrap metal, creosote-treated railroad ties and telephone poles, and a variety of construction and office debris. None of the other pits were identified as containing wastes posing potential threats to human health or the environment.

Site related soil contaminants include beryllium, lead, and benzo(a)pyrene. The material in the former disposal area requiring remedial action was estimated to be 222,000 CY. No RCRA hazardous wastes were identified at Site M13.

3.2.27.2 Summary of M13 Soils Site M13 is not located near a heavily populated or area. Site M13 will be transferred to the State of Illinois for inclusion into an industrial park. Developments within the industrial park are to include an intermodal rail system with a rail spur, additional roadways for truck traffic, and large areas reserved for warehouses. Within the SOU, the media of concern at Site M13 is associated with SRU6 soils. According to the baseline risk assessment, the media at Site M13 were not identified as a risk to industrial receptors.

3.2.28 Site M16 (Motor Pool Area) The Motor Pool Area (Area 16) is located along Hoff Road in the northern section of Site M8 and covered approximately eight acres during historical site activities. During the most active period of operations in the MFG Area, a fleet of approximately 400 vehicles was serviced regularly at the Motor Pool Area. Wastewater was generated in this area from vehicle and floor washing and steam cleaning of engines.

During typical operations, several precautions were generally taken to keep oil and grease that were removed from serviced vehicles out of the wastewater drainage system. The floor drains were equipped with traps that collected oil, grease, and settled solids. These traps were periodically removed and emptied into 55-gallon drums kept onsite. In addition, spent oil and grease from vehicle maintenance were also containerized onsite. These wastes were eventually moved to the 10,000-gallon UST located in the Salvage Yard on the LAP side of JOAAP.

A site reconnaissance was conducted at the Motor Pool Area by Dames & Moore on June 10 and 11, 1991. No visible evidence of oil staining was observed on the ground surface. Also, there

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was no evidence of a storm water discharge point from the Motor Pool to the Acid Ditch. JOAAP personnel indicated that the sewer lines at the Motor Pool may have previously discharged into the old process sewer lines from the Acid Area, which discharged into the Tetryl Ditch rather than into the Acid Ditch. No drawings could be found to determine if the old process sewer lines ever received discharge from the Motor Pool; however, in past years, oil slicks have been reported in both the Tetryl Ditch and Grant Creek, which would support this scenario.

3.2.28.1 Summary of M16 Soils Based upon data collected during the Phase 2 RI, and discussed in Table 6-3 of the October 1998 ROD, COC (TPHs, PCBs, and Base Neutral Acids [BNAs]) at Site M16 were present at concentrations that satisfied the industrial RGs designated in the October 1998 ROD. Site M16 was designated as a NFA site in the October 1998 ROD and has since been transferred to the State of Illinois, and is currently owned by CenterPoint Properties, a private entity.

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4.0 REMEDIAL ACTIONS The initial ROD for JOAAP was finalized in October 1998. The second and final ROD for JOAAP was finalized in June 2004. Remedial Action Objectives (RAOs) were developed as a result of RI and FS activities conducted at the site. The primary objective of the remedial actions at JOAAP is to effectively mitigate, minimize threats to, and provide adequate protection of human health and the environment. To meet this objective, the Army developed RAOs for both the soil and groundwater OUs.

The objectives of the final remedial actions are summarized as:

� Clean up contaminants to the site-specific and chemical-specific remediation goals

� Prevent human and environmental exposure to contamination at concentrations above the remediation goals

� Eliminate soil contamination as a continuing source of groundwater contamination

� Prevent migration of contaminants

� Actions will not leave behind any characteristically hazardous RCRA wastes, except those contained within the capped landfills of SRU6

The RGs established in the October 1998 ROD for SOU sites at JOAAP were established from a risk-based model based on the final intended use of the lands following transfer of property. Further classification of SRU sites being remediated, based on the intended land use, was developed in the October 1998 ROD. This classification considered the RGs for the Industrial Park and Will County Landfill areas as “Final”.

The 1998 ROD also presented interim soil RGs for the contaminant groups of explosives (SRU1), metals (SRU2), explosives inter-mixed with metals (SRU3), and organics (SRU5) on USDA lands (lands currently managed by or intended for the USDA for establishment of the MNTP). The objectives of the interim remedial actions were to eliminate soil contamination as a continuing source of groundwater contamination and prevent migration of contaminants.

The 1998 ROD specified that a multi-agency team develop final cleanup levels that are protective of human health and the environment for USDA lands. Two different multi-agency teams, made up of representatives from the USEPA, IEPA, Army, USDA/FS, USFWS, Illinois Department of Natural History, Illinois Department of Public Health, and the Restoration Advisory Board (RAB)(representing the community), were established to complete this task and were called the Ecological Work Group and the Human Health Work Group.

The final RGs for the interim portion of contaminant groups SRU1, SRU2, SRU3, and SRU5 were developed, evaluated, selected, and presented in the Final ROD for the Soil Operable Unit Interim Sites (U.S. Army, June 2004).

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The following subsections give a description of the selected remedy for each designated SRU where final RGs have been established. Site-specific information describing remedy implementation, system operations, and O&M activities are described in detail in further subsections.

4.1 Remedy Selection The following subsections give a summary of the selected remedy for each designated SRU as described in the October 1998 ROD or June 2004 ROD. All the selected remedies include excavation, treatment, or disposal of soil containing contaminant concentrations above the RGs.

Remedial action activities conducted at Site M6 to remove SRU1 and SRU3 soils were conducted under the remedies developed in the October 1998 ROD. RA action activities were initiated during the first five year review period and were completed during the second five year review period.

4.1.1 SRU1: Explosives in Soil – Excavation/Treatment Listed below are the RA activities under the Excavation/Treatment remedy for SRU1 soils as developed in the June 2004 ROD. The Excavation/Treatment remedy included:

�� -Sampling, Soil Excavation, Transportation, and Confirmatory Sampling �� ediation) ��

4.1.2 SRU2: Metals in Soil – Excavation/Disposal Listed and described below are the RA activities under the Excavation/Disposal remedy for SRU2 soils as developed in the June 2004 ROD. Some of the remedial actions that are common between SRUs were described in the section above and are only listed below. The Excavation/Disposal remedy includes:

� Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling � Soil Preparation � Backfilling, Regrading, and Revegetating Excavated Areas � Soil Disposal � Land Transfer Documentation

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4.1.3 SRU3: Explosives and Metals in Soil – Excavation/Disposal Listed and described below are the RA activities under the Excavation/Disposal remedy for SRU3 soils as developed in the June 2004 ROD. Some of the remedial actions that are common between SRUs were described in the section above and are only listed below. The Excavation/Disposal remedy includes:

� Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling � Soil Preparation � Backfilling, Regrading, and Revegetating Excavated Areas � Soil Disposal � Land Transfer Documentation

4.1.4 SRU4: Excavation/Incineration and Disposal Listed and described below are the RA activities under the Excavation/Incineration and Disposal remedy for SRU4 soils as developed in the October 1998 ROD. The Excavation/Incineration and Disposal remedy includes:

� Building Demolition � Soil Excavation, Transportation, and Confirmatory Sampling � Backfilling, Regrading, and Revegetating Excavated Areas � Soil Incineration or Disposal � Institutional Controls –Deed Restrictions on Land and Soils

4.1.5 SRU5: Organics in Soil – Excavation/Treatment Listed and described below are the RA activities under the Excavation/Treatment remedy for SRU5 soils as developed in the June 2004 ROD. Some of the remedial actions that are common between SRUs were described in the section above and are only listed below. The Excavation/Disposal remedy includes:

� Building Demolition � Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling � Soil Preparation � Treatment � Backfilling, Regrading, and Revegetating Excavated Areas � Soil Disposal � Treatment Area Decommissioning � Land Transfer Documentation

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4.1.6 SRU7: Removal and Recycle and Disposal Listed and described below are the RA activities under the Removal and Recycle and Disposal remedy for SRU7 soils as developed in the October 1998 ROD. The Removal and Recycle and Disposal remedy includes:

� Soil Excavation, Transportation, and Confirmatory Sampling � Backfilling, Regrading, and Revegetating Excavated Areas � Sulfur Recycle or Disposal � Institutional Controls

4.1.7 No Further Action Sites Sites L6 and M16 were identified in the October 1998 ROD as NFA sites, but have soils present at the sites that do not allow for unlimited use and unrestricted exposure. Soils at each site meet the industrial RGs set in the October 1998 ROD. These NFA sites implement institutional controls in the form of deed restrictions to verify that current land use is consistent with industrial use objectives.

4.2 Remedy Implementation Phase 1 of the remedial design for RA activities was conducted between July 1998 and April 1999 with no substantial difficulties occurring during the design. The Final Soils Operable Unit Remedial Design/Remedial Action Work Plan –Phase 1 (MWH, 1999) was approved and signed on April 7, 1999.

Phase 2 of the remedial design for RA activities was conducted between July 1998 and April 1999. The Remedial Design/Remedial Action Work Plan –Phase 2 (MWH, 2005) was approved and signed on October 7, 2005.

Additional RA activities were conducted in accordance with the following approved MKM Work Plans:

� Final M11 Work Plan for Soil Remediation Unit 6 (2007) � Final Remedial Action Work Plan for the Military Munitions Response Sites L3, L2, and

L34 (2006) � Final Remedial Action Work Plan for Remediation of Soil Operable Unit 6, M1 Landfill

(2006) � Final Remedial Action Work Plan for Remediation of Soil Operable Unit 6, M13 Landfill

(2007)

Several factors governed the order in which RA activities were conducted. The sites that posed the greatest risk to human health and the environment; based upon the baseline risk assessment, were generally the sites where RA activities were first initiated.

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Other factors affecting the order of RA activities included:

� Mitigating the highest potential for migration of COC from soil to groundwater � Necessity of quickly expediting property transfers � Budgetary constraints

The following subsections describe, on a site-by-site basis, the implementation of the selected remedies based upon SRU designation.

4.2.1 SRU1 Soils

4.2.1.1 Site L1 Remedial action activities at Site L1 were conducted from October 2005 to March 2006. The major components of the RA activities conducted at Site L1 included:

� Mobilization � Site Preparation � Water Handling � Building Demolition � Soil Excavation � Soil Transportation and Treatment � Sampling and Analysis � Storm Water Management � Decontamination � Site Restoration � Demobilization

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Remedial Design/Remedial Action Work Plan –Phase 2 Soils Operable Unit, (MWH, October 2005) (Phase 2 – Remedial Design/Remedial Action Work Plan). During RA activities, approximately 11,634 CY of unscreened SRU1 soils were excavated from Site L1 and transported to the Site M4 Bioremediation Treatment Facility (BTF) for stockpiling, screening, and treatment. Table 5 provides the volumes of soil excavated from the SRU1 sites. A total of 321 CY of concrete debris from Site L1 was transported and disposed of at the Prairie View Recycling Disposal Facility (RDF). Table 6 provides the volumes of concrete excavated from SRU1 sites.

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Site

L1 (CY)

11,634

SRU1 Soil Volume

L2 946 L7 3,860 L8 1,869 L9 4,210

L10 2,952 L14 780 L16 13 M2 13,900 M3 55 M5 1,500 M6 112,547 M7 16,923 *

TOTAL 171,189 *Value converted from tons to CY = 1.3tons/CY, M7 = 22,000tons

Table 6: SRU1 Sites - Excavated Concrete Volumes

Site

L1 (CY) 321

Concrete

L2 280 L7 445 L8 384 L9 550

L10 449 L14 0 M2 0

TOTAL 2,429

Soil samples SS452 and SS453 were excavated from near Building 61-35 as zinc anomalies according to the provisions detailed in the Phase 2 – Sampling and Analysis Plan (SAP). The zinc-impacted soils were combined with the sediment from Building 61-35 (Sump House) and properly disposed of at the Prairie View RDF. Potential Asbestos Containing Material (PACM) was removed from building 61-4 to minimize hazards to workers during excavation activities.

Remedial action activities included confirmation sampling at excavation sites consistent with the Final Phase 2 - Soils Operable Unit Sampling and Analysis Plan (Phase 2 - SAP) included as Appendix C in the Final Phase 2 - Remedial Design/Remedial Action Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU1 lower remediation goals (LRGs), upper remediation goals (URGs), or TCLP criteria established by the June 2004 ROD.

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Table 5: SRU1 Sites - Excavated Soil Volumes


Due to reasonable excavation volumes during excavation activities, soil for backfill was obtained from a clean onsite location, or from soil covering concrete bunkers. Onsite backfill materials also included soils from the topography surrounding excavations. Excavations were backfilled and regraded to prevent ponding and promote proper drainage. Revegetation was not conducted in backfilled/regraded areas. Based on historical RA activities at JOAAP, disturbed soils in excavation areas were anticipated to naturally revegetate during the ensuing growing season.

Equipment utilized during RA activities at Site L1 was decontaminated, following completion of excavation activities, and moved to other sites at JOAAP with active excavation activities. A final inspection was conducted by the USACE at the site, with concurrence of completion stated on August 22, 2006.

As part of the GMZ for explosives, existing monitoring wells at Site L1 will continue to be sampled as part of the selected natural attenuation remedy for groundwater. The natural attenuation remedy for groundwater at Site L1 is described in the GOU- Second Five-Year Review Report. Remedial action activities at Site L1 are considered complete, except for groundwater monitoring. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.

The selected remedy has successfully functioned to remove SRU1 soils above RGs from Site L1. The RAOs set forth in the June 2004 ROD have been satisfied for the site. Closure of Site L1 is documented in the Final Closure Report, Sites L1, L7, L8, L9, L10, L14, and M2 (MWH, December 2006).

4.2.1.2 Site L2 Remedial action activities at Site L2 were conducted between February 12, 2007 and October 31, 2007. The major components of the RA activities conducted at Site L2 included:

� Mobilization � Site Preparation � Water Handling � Building Demolition � Soil Excavation � Soil Transportation and Treatment � Sampling and Analysis � MEC Support � Storm Water Management � Decontamination � Site Restoration � Demobilization

Based on communications with USACE, Site L2 was cleared of MEC by USA Environmental, under contract to MWH, in 2007. Specific details regarding the location, type, and amount of

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MEC removed from Site L2 are reportedly included in an Appendix to the Final Closure Report for Site L2, which was not available at the time of our review.

A 200-foot buffer zone surrounding Site L2 was cleared of MEC during a subsequent effort completed by PIKA Engineers, under contract to MKM. Specific details regarding the location, type, and amount of MEC removed from this buffer zone are included in Site Specific Draft Final Reports for Removal Action at Munitions Response - Sites L2, L3 & L34; however, these reports were not available at the time of this review.

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 946 CY of unscreened SRU1 soils were excavated from Site L2 and transported to the Site M4 BTF for stockpiling, screening, and treatment. A total of 280 CY of concrete debris from Site L2 was transported and disposed of at the Prairie View RDF.

Remedial action activities included confirmation sampling at excavation sites consistent with the Phase 2 - SAP included as Appendix C in the Final Phase 2 - Remedial Design/Remedial Action Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU1 LRGs, URGs, or TCLP criteria established by the October 1998 and June 2004 RODs.

Due to reasonable excavation volumes during excavation activities, soil for backfill was obtained from a clean onsite location. Onsite backfill materials also included soils from the topography surrounding excavations. Where feasible, excavations were backfilled and regraded to prevent ponding and promote proper drainage. Reseeding was conducted in consultation with the USDA/FS per the June 2004 ROD, in areas deemed critical to prevent significant storm water erosion. Vegetation established in the regraded areas was consistent with the surrounding topography, and erosion control blankets were to be utilized as necessary. Silt fencing was established in critical areas to avoid sediment runoff to surrounding areas.

Equipment utilized during RA activities at Site L2 was decontaminated, following completion of excavation activities. A final inspection was conducted by the USACE at the site, following RA activities.

As part of the GMZ for Groundwater Remedial Units 1 and 3, existing monitoring wells at Site L2 will continue to be sampled as part of the selected natural attenuation remedy for groundwater. The natural attenuation remedy for groundwater at Site L2 is described in the GOU- Second Five-Year Review Report. Remedial action activities at Site L2 are considered complete, except for groundwater monitoring. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.

The selected remedy has successfully functioned to remove SRU1 soils above RGs from Site L2. The RAOs set forth in the October 1998 ROD and June 2004 ROD have been satisfied for the site. Closure of Site L2 is documented in the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

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4.2.1.3 Site L7 Remedial action activities at Site L7 were conducted from the week of July 13, 2005, through the week of February 14, 2006. The major components of the RA activities conducted at Site L7 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 3,860 CY of unscreened SRU1 soils were excavated from Site L7 and transported to the Site M4 BTF for stockpiling, screening, and treatment. A total of 445 CY of concrete debris from Site L7 was transported and disposed of at the Prairie View RDF.

The foundations of Buildings 1-40A and 1-40C were removed to facilitate access to impacted soil. Sumps S7-1 and S7-2 near Buildings 1-4 and 1-10, respectively, were removed.

Remedial action activities included confirmation sampling at excavation sites consistent with the Phase 2 - SAP included as Appendix C in the Final Phase 2 - Remedial Design/Remedial Action Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU1 LRGs, URGs, or TCLP criteria established by the June 2004 ROD.



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Remedial action activities at Site L7 are considered complete. With land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.


4.2.1.4 Site L8 Remedial action activities at Site L8 were conducted from the week of September 28, 2005, through the week of February 27, 2006. The major components of the RA activities conducted at Site L8 included:



The Foundation of Building 2-40B was removed to access impacted soil. Sump S8-1 near Building 2-6 was removed.


Due to reasonable excavation volumes during excavation activities, soil for backfill was obtained from a clean onsite location, or from soil covering concrete bunkers. Onsite backfill materials also included soils from the topography surrounding excavations. Excavations were backfilled and regraded to prevent ponding and promote proper drainage. Revegetation was not conducted

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in backfilled/regraded areas. Based on historical RA activities at JOAAP, disturbed soils in excavation areas were anticipated to naturally revegetate during the ensuing growing season.




4.2.1.5 Site L9 Remedial action activities at Site L9 were conducted from the week of October 5, 2005, through the week of June 12, 2006. The major components of the RA activities conducted at Site L9 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 4,210 CY of unscreened SRU1 soils were excavated from site L9 and transported to the Site M4 BTF for stockpiling, screening, and treatment. A total of 550 CY of concrete debris from Site L7 was transported and disposed of at the Prairie View RDF.

Sump S9-1 near Building 3-37 and Sump S9-2 near Building 3-5A were excavated and properly disposed. Soil sample SC722 was excavated from Site L9 as a thallium anomaly according to the provisions detailed in the Phase 2 – SAP. Soil sample SC718 was excavated from Site L9 as a mercury anomaly according to the provisions detailed in the Phase 2 – SAP. Soil sample SC624 was excavated from Site L9 as a thallium anomaly according to the provisions detailed in

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the Phase 2 – SAP. Soil sample SC630 was excavated from Site L9 as an arsenic anomaly according to the provisions detailed in the Phase 2 – SAP. The metals-impacted soils were transported to Prairie View RDF for disposal.

Remedial action activities included confirmation sampling at excavation sites consistent with the Phase 2 - SAP included as Appendix C in the Final Phase 2 - Remedial Design/ Remedial Action Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU1 LRGs, URGs, or TCLP criteria established by the June 2004 ROD.





4.2.1.6 Site L10 Remedial action activities at Site L10 were conducted from the week of August 17, 2005, through the week of September 27, 2005. The major components of the RA activities conducted at Site L10 included:

� Mobilization � Site Preparation � Water Handling � Building Demolition � Soil Excavation, Transportation and Treatment � Sampling and Analysis � Storm Water Management � Decontamination � Site Restoration � Demobilization

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4.2.1.7 Site L14 Remedial action activities at Site L14 were conducted from the week of July 8, 2005, through the week of August 8, 2005. The major components of the RA activities conducted at Site L14 included:

� Mobilization � Site Preparation � Water Handling � Soil Excavation, Soil Transportation and Treatment � Sampling and Analysis � Storm Water Management � Decontamination � Site Restoration � Demobilization

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USEPA and IEPA have verified that all RA activities were conducted in accordance with the Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 780 CY (including 202 CY from the three soil piles at the site) of unscreened SRU1 soils were excavated from site L14 and transported to the Site M4 BTF for stockpiling, screening, and treatment. No concrete was removed from Site L14.




As part of the GMZ for explosives, existing monitoring wells at Site L14 will continue to be sampled as part of the selected natural attenuation remedy for groundwater. Groundwater monitoring is described in the GOU - Second Five-Year Review Report. Remedial action activities at Site L14 are considered complete. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.


4.2.1.8 Site L16 RA activities for SRU1 soil and MEC removal were formally initiated at Site L16 on August 12, 2002 during the initial kick-off meeting for MEC clearance activities. The major components of the RA activities conducted at Site L16 included:

� Mobilization and Site Preparation � MEC Clearance � Soil Excavation, Transportation and Disposal � Sampling and Analysis � Restoration and Revegetation � Demobilization

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During site characterization activities conducted in the summer of 2001, EOD Technologies determined that fuses and boosters were present around a railroad tie structure. The tie structure was disassembled and all residual MEC removed. During the removal activities, a total of 107 nose fuses and fuse boosters were located. Approximately 292 lbs of MEC waste and 89 lbs of non-MEC waste were removed. Ninety percent of the total area of L16 was cleared. The remaining ten percent around the perimeter of the concrete foundation remained to be cleared due to a lack of funding. Remaining wastes were removed during the 2002 RA activities. No RCRA hazardous wastes were identified at Site L16.

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Soils Operable Unit Remedial Design/ Remedial Action Work Plan –Phase 1 (MWH, April 1999). During RA activities between August 12 and August 15, 2002 approximately 900 lbs of MEC waste were removed, screened, and transported offsite from around the perimeter of the concrete foundation. Excavation activities were conducted on October 10, 2002 and July 30, 2003 to remove a total of approximately 13 CY of SRU1 soils. The soils were transported offsite to Site M6, screened, then transported to the BFT and treated in Windrows 115, 149, and 150.

Regrading and backfilling of the site was performed only at the sump removal locations. Demobilization activities took place on August 28, 2002, after sump excavation, and on October 10, 2002, after sump backfilling and soil excavation/transporting.

The deed restriction covering the industrial park at Site L16 will limit future soil and groundwater use. The land in areas designated for the industrial park may not be used for residential purposes. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.

The selected remedy has successfully functioned to remove SRU1 soils above RGs and MEC waste from Site L16. The RAOs set in the October 1998 ROD have been satisfied for the site. Closure of Site L16 is documented in the Final Closure Report, Sites L11/L16 (MWH, December 2003).

4.2.1.9 Site M2 Remedial action activities at Site M2 were conducted from the week of March 29, 2006, through the week of July 7, 2006. The major components of the RA activities conducted at Site M2 included:

� Mobilization � Site Preparation � Water Handling � Soil Excavation, Transportation and Treatment � Sampling and Analysis � Storm Water Management � Decontamination � Site Restoration � Demobilization

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USEPA and IEPA have verified that all RA activities were conducted in accordance with the Phase 2 – Remedial Design/ Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 13,900 CY of unscreened SRU1 soils were excavated from site M2 and transported to the Site M4 BTF for stockpiling, screening, and treatment. No concrete was removed from Site M2.


Due to the greater than anticipated excavation quantities at site M2, treated soil from the Site M4 BTF was utilized as a source of backfill material. Following approval by the USEPA, IEPA, and USDA/FS, approximately 17,055 CY of treated SRU1 soil was used as backfill material in the site M2 excavation. Excavations were backfilled and regraded to prevent ponding and promote proper drainage. Revegetation was not conducted in backfilled/regraded areas. Based on historical RA activities at JOAAP, disturbed soils in excavation areas were anticipated to naturally revegetate during the ensuing growing season.

Equipment utilized during RA activities at Site M2 was decontaminated, following completion of excavation activities, and moved to other sites at JOAAP with active excavation activities. A final inspection was conducted by the USACE at the site, with concurrence of completion stated on August 22, 2006.

Remedial action activities at Site M2 are considered complete. With land use restrictions in place, the site is ready to be transferred for its intended recreational use.

The selected remedy has successfully functioned to remove SRU1 soils above RGs from Site M2. The RAOs set forth in the June 2004 ROD have been satisfied for the site. Closure of Site M2 is documented in the Final Closure Report, Sites L1, L7, L8, L9, L10, L14, and M2 (MWH, December 2006).

4.2.1.10 Site M3 Remedial action activities at Site M3 were conducted between July 6, 2006 and September 25, 2007. The major components of the RA activities conducted at Site M3 included:

� Mobilization � Site Preparation � Water Handling � Soil Excavation, Soil Transportation and Treatment � Sampling and Analysis � Storm Water Management � Decontamination � Site Restoration � Demobilization

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USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 55 CY of unscreened SRU1 soils were excavated from site M3 and transported to the Site M4 BTF for stockpiling, screening, and treatment. No concrete was removed from Site M3.


Due to reasonable excavation volumes during excavation activities, soil for backfill was obtained from a clean onsite location. Onsite backfill materials also included soils from the topography surrounding excavations. Where feasible, excavations were backfilled and regraded to prevent ponding and promote proper drainage. Reseeding was conducted in consultation with the USDA/FS per the June 2004 ROD, in areas deemed critical to prevent significant storm water erosion. Vegetation established in the regraded areas was consistent with the surrounding topography, and erosion control blankets were utilized as necessary. Silt fencing was established in critical areas to avoid sediment runoff to surrounding areas.

Equipment utilized during RA activities at Site M3 was decontaminated, following completion of excavation activities. A final inspection was conducted by the USACE at the site, following RA activities.

As part of the GMZ for Groundwater Remedial Units 1 and 3, existing monitoring wells at Site M3 will continue to be sampled as part of the selected natural attenuation remedy for groundwater. The natural attenuation remedy for groundwater at Site M3 is described in the GOU- Second Five-Year Review Report. Remedial action activities at Site M3 are considered complete, except for groundwater monitoring. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use.

The selected remedy has successfully functioned to remove SRU1 soils above RGs from Site M3. The RAOs set forth in the October 1998 and June 2004 ROD have been satisfied for the site. Closure of Site M3 is documented in the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

4.2.1.11 Site M6 The majority of soils at Site M6, as characterized in the RI/FS, were determined to be SRU1 soils, with the remainder being SRU3 soils. The selected remedy at Site M6, for both SRU1 and SRU3 soils, was the same – Excavation and Treatment (Bioremediation). For these reasons, the discussion pertaining to SRU3 soils at Site M6 has been summarized under the SRU1 heading.

Remedial action activities for SRU1 and SRU3 soils removal were formally initiated at Site M6 on July 16, 1999 during the pre-construction kick-off meeting.

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The major components of the RA activities conducted at Site M6 since the start of construction included:

� Mobilization � Site Preparation � Water Handling � Building Demolition � Soil Excavation � Soil Transportation and Treatment � Sampling and Analysis � Raw Product and MEC Support � Storm Water Management � Decontamination � Site Restoration � Demobilization

The main rail line and spurs were located on the eastern edge of Site M6 and extended the entire length of the site. The main rail line was approximately 6,000 feet long and had 35 rail spurs that ran off at a slight angle to the southwest and were approximately 200 feet in length. The rail lines themselves were salvaged for scrap in 1998 prior to initiation of RA activities.

Excavation activities within Site M6 commenced August 23, 1999 and were conducted using conventional excavation equipment. Based on the Phase 1 Remedial Design/Remedial Action Work Plan and the preliminary characterization sampling results, an excavation plan was prepared for each designated area. Excavation of contaminated soil began at Line 1 and proceeded north, line by line. Excavated materials were loaded directly onto transport vehicles.

As part of 1999 field sampling activities, USACE conducted additional site investigations of locations within the Site M6 North (Continuous Lines Area) which were not previously covered in the RI/FS but suspected of containing soil contamination. The site investigation and characterization indicated that explosives contamination was limited to discrete locations and in suspected surface-level contaminated soil beneath the elevated red-water discharge pipe.

Based on the results of the 1999 characterization effort, USACE developed a comprehensive characterization plan in 2003 designed to locate and identify any additional or outstanding explosives-contaminated soil along the main rail line and spurs not identified during 1999 characterization sampling activities.

Excavation activities were conducted in a manner to segregate SRU1 soils from SRU3 soils based on delineation indicated on the design drawings from the Phase 1 Remedial Design/ Remedial Action Work Plan. Within Site M6, the Wash Houses were the only areas characterized with SRU3 soils. SRU1 soils were stockpiled separately from SRU3 soils at the Site M4 BTF. In addition, care was taken to segregate loads of demolition debris from those containing predominantly soil.

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Visual field observation and confirmation sampling was used to verify that the remaining soils in excavated areas did not exceed the RGs and TCLP standards. Confirmation sampling for the excavated areas was conducted in accordance with the SOU SAP dated June 1999. Further, a visual inspection was completed in the remediated areas in the days immediately following the excavation activity. This delay allowed any soil contaminated with fugitive TNT or DNT to stain the soil red, reacting with the oxygen in the air and the sunlight.

When visual inspection and confirmation sampling indicated that clean-up goals had been achieved, excavation activities were considered complete. When confirmation sampling indicated that RGs and/or TCLP standards had not been met, additional excavation and additional confirmation sampling was completed until RGs were achieved.

With some exceptions, the excavation plan was completed as described in the Phase 1 Remedial Design/Remedial Action Work Plan. Over-excavation was required throughout Site M6 resulting in additional depth within and around most of the building excavations.

Backfilling and regrading activities for excavations at Site M6 were conducted in accordance with the Phase 1 - Remedial Design/Remedial Action Work Plan. Excavations were backfilled and regraded to cover exposed groundwater, prevent ponding, blend excavations into existing topography, and verify that site safety was maintained. Excavations were either backfilled with clean offsite borrow material, or were regraded with soils from the surrounding topography. Soil from the sand and gravel pit located to the south of Site M6 was used as a borrow source for the restoration and backfilling activities. Any excavations not backfilled and regraded had fencing constructed around its perimeter to prevent accidental entry by humans and wildlife.

The final conditions, prior the backfilling and regrading activities are considered to match the excavation figures presented in the Table 7.

Table 7: Site M6 Excavation Volumes

Year/Activity Total Soil Volume

Excavated (tons)

SRU1 Soil Volume (tons)

SRU3 Soil Volume (tons)

Truckloads

1999 M6 RA Excavation Volumes August 12 – December 16, 1999 62,342 59,684 2,658 5,229

2002 M6 RA Excavation Volumes July 18 – November 15, 2002 44,283 44,283 0 2,474

2003 M6 RA Excavation Volumes August 22 – November 14, 2003 24,014 8,580 15,434 1,470

2004-2005 M6 RA Excavation Volumes January 10, 2004 - February 18, 2005 60,823 0 60,823 5,102 (1)

1999 – 2005 TOTAL 191,462 112,547 78,915 14,275

Note: Conversion rate for tons to CY of soil = 1.3tons/CY (1) = Estimated value based upon average quantity of soil per truckload during 1999 activities

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During the 2000 construction season, additional excavation activities and sampling activities were conducted at the Site M6 North Continuous Lines Area from June 14, 2000 to July 11, 2000. A total of 1,411 tons of soils was excavated and transported to the Site M4 BTF for treatment. Confirmation sampling activities verified that excavation areas satisfied RGs set in the October 1998 ROD. Site M6 North has attained closure status as documented in the Final Site M6 North Closure Report (Montgomery Watson, December 2000).

During the 2003 and 2004 construction seasons, excavation and confirmation sampling activities were conducted along the former main rail line and rail spurs at Site M6. Excavation and sampling activities indicate that all locations where SRU1 soils above RGs were detected were excavated and transported to the Site M4 BTF.

During the 2004 and 2005 construction seasons excavation and confirmation sampling activities were conducted along the former main rail line, rail spurs, and TNT ditch at Site M6. Excavation and sampling activities indicate that all locations where SRU1 and SRU3 soils were detected above RGs were excavated and transported to the Site M4 BTF for stockpiling, screening, and treatment.

RA activities were conducted in accordance with the Final Soils Operable Unit Remedial Design/ Remedial Action Work Plan – Phase 1 (MWH, April 1999). No difficulties were encountered during the remedial design phase of the project. Remedial action activities have effectively functioned to meet RAOs at the sites where RGs have been satisfied.

Remedial Actions are complete. The land use restrictions covering Site M6 will limit future soil and groundwater use. With land use restrictions in place, the site is ready to be transferred. The land in areas designated for the industrial park may not be used for residential purposes.

The selected remedy has successfully functioned to remove SRU1 and SRU3 soils above RGs from Site M6. The RAOs set forth in the October 1998 ROD have been satisfied for the site. Closure of Site M6 is documented in the Final Closure Report, Site M6 (MWH, June 2006).

4.2.1.12 Site M7 Remedial action activities for SRU1 soils removal were formally initiated at Site M7 on July 10, 2001 with the commencement of construction mobilization activities. The major components of the RA activities conducted at Site M7 included:

� Mobilization � Site Preparation � Water Handling � Soil Excavation � Sampling and Analysis � Soil Screening and Transportation � Pipe and Sump Removal � Site Restoration � Demobilization

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USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Soils Operable Unit Remedial Design/Remedial Action Work Plan – Phase 1 (MWH, April 1999). During RA activities, approximately 22,000 tons (1.3 tons/CY) SRU1 soils were excavated, transported offsite and screened, and treated at the Site M4 BTF. Soils excavated from Site M7 were successfully treated in Windrows 65 through 85. All SRU1 soils from Site M7 have been excavated to meet RGs; and RAOs set in the October 1998 ROD have been satisfied. USACE conducted a final inspection on November 19, 2001 and the final inspection certificate of completion was received on November 27, 2001 by MWH. Site regrading and restoration activities have been conducted to the level appropriate, based upon future use of the property for industrial purposes. All equipment and materials involved with RA activities were demobilized from the site.

Deed restrictions covering Site M7 will limit future soil and groundwater use.

The selected remedy has successfully functioned to remove SRU1 soils above RGs from Site M7, and the RAOs set forth in the October 1998 ROD have been satisfied. Closure of Site M7 is documented in the Final Closure Report, Site M7 (MWH, November 2003).

4.2.2 SRU2 Soils

4.2.2.1 Site L2 Remedial action activities at Site L2 were conducted between February 12, 2007 and October 31, 2007. The major components of the RA activities conducted at Site L2 included:

� Mobilization � Site Preparation � Water Handling � Building Demolition � Soil Excavation � Soil Transportation and Disposal � Sampling and Analysis � MEC Support � Storm Water Management � Decontamination � Site Restoration � Demobilization

Based on communications with USACE, Site L2 was cleared of MEC by USA Environmental, under contract to MWH, in 2007. Specific details regarding the location, type, and amount of MEC removed from Site L2 are reportedly included in an Appendix to the Final Closure Report for Site L2, which was not available at the time of our review.

A 200-foot buffer zone surrounding Site L2 was cleared of MEC during a subsequent effort completed by PIKA Engineers, under contract to MKM. Specific details regarding the location,

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type, and amount of MEC removed from this buffer zone are included in Site Specific Draft Final Reports for Removal Action at Munitions Response - Sites L2, L3 & L34; however, these reports were not available at the time of this review.

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 7,092 CY of unscreened SRU2 soils were excavated from Site L2 and transported to the Prairie View DRF for disposal. The volume of concrete excavated from site L2 is provided above in Table 6.

Remedial action activities included confirmation sampling at excavation sites consistent with the Phase 2 - SAP included as Appendix C in the Final Phase 2 - Remedial Design/ Remedial Action Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU2 LRGs, URGs, or TCLP criteria established by the October 1998 and June 2004 RODs. Table 8 provides the volumes of excavated soil from SRU2.

Table 8: SRU2 Sites - Excavated Soil Volumes

Site SRU2 Soil Volume (CY) L2 7,092 L5 1,383

L11 15 L23A 5,492 M3 23,612* M4 8,150 M12 8,457

TOTAL 54,201 * - Includes SRU2 and SRU3 soils



Remedial action activities at Site L2 are considered complete, except for groundwater monitoring. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.

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The selected remedy has successfully functioned to remove SRU2 soils above RGs from Site L2. The RAOs set forth in the October 1998 and June 2004 ROD have been satisfied for the site. Closure of Site L2 is documented in the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

Following RA activities, soil and sediment containing COC above RGs were removed, thereby minimizing the risk to human health and the environment.

This area was identified for excavation and disposal as commingled metals- and explosives-contaminated soils.

4.2.2.2 Site L3 Remedial action activities were conducted in accordance with the Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). Remedial action activities were conducted at Site L3 to satisfy the final RGs for SRU2 and SRU3 soils and RAOs stated in the 2004 ROD.

Upon designation of final RGs for Site L3, RD/RA activities were conducted in accordance with the decision documents developed by USEPA, IEPA, and USACE to effectively design and implement the selected remedies for SRU2 and SRU3 soils.

Based on communications with USACE, Site L3 was cleared of MEC by USA Environmental, under contract to MWH, in 2007. Specific details regarding the location, type, and amount of MEC removed from Site L3 are reportedly included in an Appendix to the Final Closure Report for Site L3, which was not available at the time of our review. A 200-foot buffer zone surrounding Site L3 was cleared of MEC during a subsequent effort completed by PIKA Engineers, under contract to MKM. Specific details regarding the location, type, and amount of MEC removed from this buffer zone are included in Site Specific Draft Final Reports for Removal Action at Munitions Response - Sites L2, L3 & L34; however, these reports were not available at the time of this review.

RA activities at Site L3 have been completed however; the Final Closure Report has not been approved as of the writing of this review.

4.2.2.3 Site L5 Remedial action activities and MEC clearance at Site L5 were conducted between June 6, 2007 and September 18, 2007. The major components of the RA activities conducted at Site L5 included:

� Mobilization � Site Preparation � Water Handling � Building Demolition

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� Soil Excavation � Soil Transportation and Disposal � Sampling and Analysis � MEC Support � Storm Water Management � Decontamination � Site Restoration � Demobilization

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 1,383 CY of unscreened SRU2 soils were excavated from Site L5 and transported to the Prairie View DRF for disposal. No concrete was removed from Site L5.




Site L5 has not received final closure. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.

According to the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008), activities to address metals and TPH-impacted soils were ongoing at the Site L5 former junk pile area. RA activities at Site L5 have since been completed however; the Final Closure Report has not been approved as of the writing of this review.

4.2.2.4 Site L11 Remedial action activities for SRU2 soils and MEC removal were formally initiated at Site L11 on August 12, 2002 during the initial kick-off meeting for MEC clearance activities.

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The major components of the RA activities conducted at Site L11 included:

� Mobilization � Site Preparation � MEC Clearance � Soil Excavation � Sampling and Analysis � Soil Transportation and Disposal � Restoration and Revegetation � Demobilization

USEPA and IEPA have determined that all RA activities were conducted in accordance with the Final Soils Operable Unit Remedial Design/Remedial Action Work Plan – Phase 1 (MWH, April 1999). During RA activities, approximately 152 lbs of MEC waste and 15 CY of arsenic contaminated SRU2 soils were excavated, transported offsite, and properly disposed.

Excavation depths did not exceed one foot in depth and the topography of the site is flat. Since the potential for soil erosion was minimal, regrading was not required. Due to the relatively small size of the excavation, no site revegetation or restoration of the excavation areas was required.

The land use restriction covering the industrial park at Site L11 will limit future soil and groundwater use. Existing site fencing serves as a deterrent to unauthorized entry to the site. The land in areas designated for the industrial park may not be used for residential purposes.

On November 26, 2002, the roll-off containers were collected by Waste Management and disposed at the permitted Laraway Landfill located at 21101 W Laraway Rd, Elwood, IL. Upon removal of the roll-off containers, site demobilization was complete.

The selected remedy has successfully functioned to remove SRU2 soils above RGs and MEC waste from Site L11. The RAOs set forth in the October 1998 ROD have been satisfied for the site. Closure of Site L11 is documented in the Final Closure Report, Sites L11/L16 (MWH, December 2003).

During MEC site characterization activities, conducted in the summer of 2001, 31 acres of Site L11 were characterized for UXO/EO prior to removal activities. EOD Technologies (Knoxville, TN) identified one 40mm HE grenade M406 and 190 pounds of non-MEC scrap. During MEC removal activities at L11 that same year, EOD Technologies removed a total of five MEC items, 10 lbs. of MEC scrap, and 1 lb. of non-MEC scrap. MEC removal activities at Site L11 were conducted within an area of approximately four acres. The characterization could not be followed up with complete removal at the time due to funding constraints.

During RA activities conducted during 2002, excavation and confirmation sampling activities were conducted to remove all SRU2 soils above RGs. MEC clearance activities were also conducted to remove any MEC items that were not detected during historical clearance activities.

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During these RA activities approximately 15 CY of arsenic contaminated (SRU2) soils and 152 lbs of MEC waste were excavated and properly disposed of from Site L11.

Following RA activities, soil-containing COC above RGs and MEC waste were removed, thereby minimizing the risk to human health and the environment.

According to the RAOs set forth in the October 1998 ROD, Site L11 has achieved closure status as part of the SOU as documented in the Final Closure Report – Sites L11/L16 (MWH, December 2003).

4.2.2.5 Site L23A Remedial action activities at Site L23A were conducted between April 5, 2007 and May 18, 2007. The major components of the RA activities conducted at Site L23A included:

� Mobilization � Site Preparation � Soil Excavation � Soil Transportation and Disposal � Sampling and Analysis � Storm Water Management � Decontamination � Site Restoration � Demobilization

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 5,492 CY of unscreened SRU2 soils were excavated from site L23A and transported to the Prairie View DRF for disposal. No concrete was removed from Site L23A.



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Equipment utilized during RA activities at Site L23A was decontaminated, following completion of excavation activities. A final inspection was conducted by the USACE at the site, following RA activities.

Remedial action activities at Site L23A are considered complete. With land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.

The selected remedy has successfully functioned to remove SRU2 soils above RGs from Site L23A. The RAOs set forth in the October 1998 and June 2004 ROD have been satisfied for the site. Closure of Site L23A is documented in the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

4.2.2.6 Site M3 The majority of soils at Site M3, as characterized in the RI/FS, were determined to be SRU2 soils. Explosives contamination is commingled with the lead contamination, but metal contamination is the driving force for clean-up of Site M3. For these reasons, the discussion pertaining to SRU3 soils at Site M3 has been summarized under the SRU2 heading.

Remedial action activities at Site M3 were conducted between July 6, 2006 and September 25, 2007. The major components of the RA activities conducted at Site M3 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 23,612 CY of unscreened SRU2 and SRU3 soils were excavated from Site M3 and transported to the Prairie View DRF for disposal. No concrete was removed from Site M3.

Remedial action activities included confirmation sampling at excavation sites consistent with the Phase 2 - SAP included as Appendix C in the Final Phase 2 - Remedial Design/Remedial Action Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU2 or SRU3 LRGs, URGs, or TCLP criteria established by the October 1998 and June 2004 RODs.

Due to reasonable excavation volumes during excavation activities, soil for backfill was obtained from a clean onsite location. Onsite backfill materials also included soils from the topography

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surrounding excavations. Where feasible, excavations were backfilled and regraded to prevent ponding and promote proper drainage. Reseeding was conducted in consultation with the USDA/FS per the June 2004 ROD, in areas deemed critical to prevent significant storm water erosion. Vegetation established in the regraded areas was consistent with the surrounding topography, and erosion control blankets were utilized as necessary. Silt fencing was established in critical areas to avoid sediment runoff to surrounding areas.


Remedial action activities at Site M3 are considered complete, except for groundwater monitoring. Groundwater monitoring is described in the GOU-Second Five-Year Review Report. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use.

The selected remedy has successfully functioned to remove SRU2 and SRU3 soils above RGs from Site M3. The RAOs set forth in the October 1998 ROD and June 2004 ROD have been satisfied for the site. Closure of Site M3 is documented in the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

4.2.2.7 Site M4 Remedial action activities at Site M4 were conducted between December 6, 2006 and September 24, 2007. The major components of the RA activities conducted at Site M4 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 8,150 CY of unscreened SRU2 soils were excavated from Site M4 and transported to the Prairie View DRF for disposal. No concrete was removed from Site M4.


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The selected remedy has successfully functioned to remove SRU2 soils above RGs from Site M4. The RAOs set forth in the June 2004 ROD have been satisfied for the site. Closure of Site M4 is documented in the Draft Final Closure Report – Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

4.2.2.8 Site M12 The majority of soils at Site M12, as characterized in the RI/FS, were determined to be SRU2 soils. A small volume of SRU7 soil was also located at the site that was mixed in with the SRU2 soil prior to disposal. For these reasons, the discussion pertaining to SRU7 soils at Site M12 has been summarized under the SRU2 heading.

Remedial action activities at Site M12 were conducted between November 14, 2006 and September 26, 2007. The major components of the RA activities conducted at Site M12 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 8,469 CY of unscreened SRU2 and SRU7 soils were excavated from Site M4 and transported to the Prairie View DRF for disposal. The SRU7 soils were

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handpicked during a visual sweep of the area identified in the Final Phase 2 - Remedial Design/ Remedial Action Work Plan for Site M12. Due to their small volume (approximately 12 CY), SRU7 soils were mixed with the SRU2 soils prior to disposal. No concrete was removed from Site M4.





The selected remedy has successfully functioned to remove SRU2 and SRU7 soils above RGs from Site M12. The RAOs set forth in the October 1998 and June 2004 ROD have been satisfied for the site. Closure of Site M12 is documented in the Draft Final Closure Report, Sites L2, L5, L23A, M3, M4, and M12 (MWH, March 2008).

4.2.3 SRU3 Soils

4.2.3.1 Site M5 The majority of soils at Site M5, as characterized in the RI/FS, were determined to be SRU3 soils. Furthermore, due to the relatively low concentrations of lead in the SRU3 soils, the selected remedy for SRU3 soils was designated as “Excavation and Bioremediation”. For these reasons, the discussion pertaining to SRU1 soils at Site M5 has been summarized under the SRU3 heading.

Remedial action activities for SRU3 and SRU1 soil removal were formally initiated at Site M5 on July 7, 1999 upon commencement of site preparation activities.

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The major components of the RA activities conducted at Site M5 included:

� Site Preparation � Excavation Activities � Sampling and Analysis � Soil Transportation and Disposal � Restoration and Revegetation

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Soils Operable Unit Remedial Design/Remedial Action Work Plan – Phase 1 (MWH, April 1999). During RA activities, approximately 4,100 CY of SRU3 soils, and 1,500 CY of SRU1 soils were excavated, transported offsite and screened, and treated at the Site M4 BTF. SRU3 soils were successfully treated in Windrows 152-153, 157-159, 163-166, and 169. Active treatment of SRU1 soils utilizing bioremediation was not required based upon confirmation sampling of the stockpile of SRU1 tetryl soils. Confirmation sampling results verified that ultraviolet (UV) radiation successfully degraded tetryl soils to meet RGs. Documentation of the confirmation sampling plan and results is presented in the Draft Treatment Completion Report – SRU1 Tetryl Soils (MWH, February 2004).

Treated SRU3 and SRU1 soils at Site M4 have been disposed.

Regrading and Restoration activities were completed following verification that remaining soils at Site M5 were below RGs and TCLP standards. Vegetative cover has been established at Site M5. Demobilization of RA activities is complete.

The selected remedy has successfully functioned to remove SRU3 and SRU1 soils above RGs from Site M5. The RAOs set forth in the October 1998 ROD have been satisfied for the site. Closure of Site M5 is documented in the Final Site M5 Closure Report (MWH, December 2000).

The State of Illinois acquired the deed for land area of Site M5 in August 2000. The site has been developed into an intermodal rail facility and is currently owned by CenterPoint Properties, a private entity. CenterPoint Properties submits certification of compliance for implementation of institutional controls, specified in the property deed, to the Army on an annual basis.

Remedial action activities were conducted from July to November 1999. Approximately 1,500 CY of SRU1 soils and 4,100 CY of SRU3 soils were excavated from Site M5 and delivered to the Site M4 BTF for biological treatment and disposal. Confirmation sampling verified that remaining soils did not exceed the SRU1 or SRU3 RGs established in the October 1998 ROD.

All SRU1 and SRU3 soils above RGs from Site M5 have been excavated, screened, transported and successfully treated at the Site M4 BTF to meet RGs, and RAOs set in the October 1998 ROD have been met Treatment results for SRU1 soils can be located in the Draft Treatment Completion Report – SRU1 Tetryl Soils (MWH, February 2004). Following RA activities, soil and sediment containing COC above RGs were removed, thereby minimizing the risk to human health and the environment.

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According to the RAOs set forth in the October 1998 ROD, Site M5 has achieved closure status as part of the SOU as documented in the Final Site M5 Closure Report (MWH, December 2000).

4.2.4 SRU4 Soils

4.2.4.1 Sites L1, L7, L8, L9, L10, and L17 Six SRU4 sites within the LAP Area (L1, L7, L8, L9, L10, and L17) were targeted for cleanup in 1999. PCB contamination at five of the six sites (Site L17 is the exception) resulted from leaks and spills associated with formerly used transformers. The execution of the selected remedy for SRU4 soils at each site was similar (Excavation and Disposal). All SRU4 related COC above RGs for soils have been removed from each site, and all sites have achieved closure status for SRU4 soils. Because of these factors, the discussion below is pertinent to implementation of the selected remedy for all sites with SRU4 soils.

RA activities for SRU4 soil removal at Sites L1, L7, L8, L9, L10, and L17 were formally initiated in July 1999 upon commencement of site preparation activities. The major components of the RA activities conducted at the SRU4 sites included:

� Preliminary Characterization � Contamination Delineation � Mobilization / Site Preparation � Soil Excavation, Transportation, and Disposal � Sampling and Analysis � Site Restoration

USEPA and IEPA have determined that all RA activities were conducted in accordance with the Final Soils Operable Unit Remedial Design/Remedial Action Work Plan – Phase 1 (MWH, April 1999). During RA activities at the SRU4 sites, approximately 3,950 CY of SRU4 soils were excavated, transported and disposed of an appropriate offsite disposal facility. SRU4 soils with PCB concentrations greater than 50 ppm were disposed of at RCRA Subtitle C landfill by Wayne Disposal, Belleville, Michigan. SRU4 soils with PCB concentrations less than 50 ppm were disposed of at the permitted Laraway Landfill located at 21101 W Laraway Rd, Elwood, IL.

Land use restrictions have been developed separately from the October 1998 ROD by the Army, USEPA, IEPA, USDA, and JADA. These land use restrictions will run with the land until removed by mutual agreement of the Army, USEPA, IEPA, USDA and JADA. Land in the areas designated for industrial park (Site L17) cannot be used for residential use. Land designated for the USDA (Sites L1, L5, L7, L8, L9, and L10) cannot be used for industrial or residential use.

Following RA activities, the sites were backfilled and graded to facilitate surface water drainage, consistent with the surrounding topography. Vegetative cover has been established at the SRU4 sites. Demobilization of RA activities is complete.

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The selected remedy has successfully functioned to remove SRU4 soils above RGs from the sites. During RA activities conducted in 1999, SRU4 and related COC above RGs were removed to minimize the risk to human health and the environment. The RAOs set forth in the October 1998 ROD have been satisfied for the sites as pertaining to the removal of SRU4 soils. Closure of Sites L1, L7, L8, L9, L10, and L17 for SRU4 soils is documented in the Final PCB Sites RA Closure Report (MWH, December 2001).

Remedial action activities were conducted between August and October 1999 to remove PCB-contaminated soil from Site L1. Remedial action activities resulted in the excavation of 155 CY of non-TSCA regulated soil from Site L1. RGs and RAOs set forth in the October 1998 ROD for SRU4 soils have been met.

Remedial action activities were conducted between August and October 1999 to remove PCB-contaminated soil from Site L7. Remedial action activities resulted in the excavation of 1,245 CY of PCB-contaminated (Aroclor 1260) soil and concrete. Both TSCA and non-TSCA regulated soil and concrete were managed; 1,110 CY was TSCA regulated and 135 CY was non-TSCA regulated.

Remedial action activities were conducted between August and October 1999 to remove PCB-contaminated soil from Site L8. Remedial action activities resulted in excavation of 631 CY of PCB-contaminated (Aroclor 1260) materials. Both TSCA and non-TSCA regulated materials were managed; 54 CY was TSCA regulated and 577 CY was non-TSCA regulated.

Remedial action activities were conducted between August and October 1999 to remove PCB contaminated soil from Site L9. Remedial action activities resulted in excavation of 694 CY of PCB-contaminated (Aroclor 1260) material. Both TSCA and non-TSCA regulated materials were managed; 162 CY was TSCA regulated and 532 CY was non-TSCA regulated.

Remedial action activities were conducted between August and October 1999 to remove PCB-contaminated soil from Site L10. SRU4 soils were removed from discrete locations not located near areas of explosives contaminated (SRU1) soils. Remedial action activities resulted in excavation of 1,147 CY of PCB-contaminated (Aroclor 1260) materials. Both TSCA and non-TSCA regulated materials were managed (760 CY was TSCA regulated and 387 CY was non-TSCA regulated).

Remedial action activities were conducted between August and October 1999 to remove PCB contaminated soil from Site L17. Remedial action activities resulted in excavation of 78 CY of TSCA regulated soil.

4.2.4.2 Site L5 Remedial action activities at Site L5 were conducted between June 6, 2007 and September 18, 2007. The major components of the RA activities conducted at Site L5 included:

� Mobilization � Site Preparation � Water Handling

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� Building Demolition � Soil Excavation � Soil Transportation and Disposal � Sampling and Analysis � MEC Support � Storm Water Management � Decontamination � Site Restoration � Demobilization

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 27,603 CY of unscreened SRU4 soils were excavated from Site L5 and transported to the Prairie View DRF for disposal. No concrete was removed from Site L5.






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4.2.5 SRU5 Soils

4.2.5.1 Site L1 Remedial action activities at Site L1 were conducted from October 2005 to March 2006. The major components of the RA activities conducted at Site L1 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Remedial Design/Remedial Action Work Plan –Phase 2 Soils Operable Unit, (MWH, October 2005) (Phase 2 – Remedial Design/ Remedial Action Work Plan). During RA activities, approximately 1,895 CY of unscreened SRU5 soils were excavated from Site L1 and transported to the Site M4 BTF for stockpiling, screening, and treatment. A total of 321 CY of concrete debris from Site L1 was transported and disposed of at the Prairie View RDF.

Three aboveground storage tanks (ASTs) were removed, two from north of Building 61-2, and one from west of Building 61-1, due to their deteriorating condition.

Remedial action activities included confirmation sampling at excavation sites consistent with the Final Phase 2 - Soils Operable Unit Sampling and Analysis Plan (Phase 2 - SAP) included as Appendix C in the Final Phase 2 - RD/RA Work Plan. Confirmation sampling has verified that remaining soils do not exceed SRU5 LRGs, URGs, or TCLP criteria established by the June 2004 ROD.

Site restoration activities are described above in section 4.2.1.1.


As part of the GMZ for explosives, existing monitoring wells at Site L1 will continue to be sampled as part of the selected natural attenuation remedy for groundwater. The natural attenuation remedy for groundwater at Site L1 is described in the GOU-Second Five-Year

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Review Report. Remedial action activities at Site L1 are considered complete, except for groundwater monitoring. With monitoring procedures and land use restrictions in place, the site is ready to be transferred for its intended recreational use. Existing LAP area fencing serves as a deterrent to unauthorized entry to the site.


4.2.5.2 Site L5 Remedial action activities at Site L5 were conducted between June 6, 2007 and September 18, 2007. The major components of the RA activities conducted at Site L5 included:

� Mobilization � Site Preparation � Water Handling � Building Demolition � Soil Excavation � Soil Transportation and Treatment � Sampling and Analysis � MEC Support � Storm Water Management � Decontamination � Site Restoration � Demobilization

USEPA and IEPA have verified that all RA activities were conducted in accordance with the Final Phase 2 – Remedial Design/Remedial Action Work Plan (MWH, October 2005). During RA activities, approximately 344 CY of unscreened SRU5 soils were excavated from Site L5 and transported to the Site M4 BTF for stockpiling, screening, and treatment. No concrete was removed from Site L5.


Due to reasonable excavation volumes during excavation activities, soil for backfill was obtained from a clean onsite location. Onsite backfill materials also included soils from the topography surrounding excavations. Where feasible, excavations were backfilled and regraded to prevent ponding and promote proper drainage. Reseeding was conducted in consultation with the USDA/FS per the June 2004 ROD, in areas deemed critical to prevent significant storm water erosion. Vegetation established in the regraded areas was consistent with the surrounding

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topography, and erosion control blankets were utilized as necessary. Silt fencing was established in critical areas to avoid sediment runoff to surrounding areas.




4.2.6 SRU6 Soils

4.2.6.1 Sites L3 Remedial action activities were conducted at Site L3 to satisfy the final RGs for SRU6 soils and RAOs stated in the October 1998 ROD.

The major components of the selected remedy for SRU6 soils at Site L3 included:

� Capping � Institutional Controls

Land use restrictions will be developed separately from the October 1998 ROD by the Army, USEPA, and IEPA. These land use restrictions will run with the land until removed by mutual agreement of the Army, USEPA, and IEPA. Land designated for the USDA (Site L3) cannot be used for industrial or residential use.

RA activities were conducted at Site L3 to address SRU6 soils by constructing a RCRA Subtitle D landfill cap at the site.

Based on communications with USACE, Site L3 was cleared of MEC by USA Environmental, under contract to MWH, in 2007. Specific details regarding the location, type, and amount of MEC removed from Site L3 are reportedly included in an Appendix to the Final Closure Report for Site L3, which was not available at the time of our review. A 200-foot buffer zone surrounding Site L3 was cleared of MEC during a subsequent effort completed by PIKA Engineers, under contract to MKM. Specific details regarding the location, type, and amount of MEC removed from this buffer zone are included in Site Specific Draft Final Reports for Removal Action at Munitions Response - Sites L2, L3 & L34; however, these reports were not available at the time of this review.

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RA activities at Site L3 have been completed however; the Final Closure Report has not been approved as of the writing of this review.

4.2.6.2 Site L4 Remedial action activities at Site L4 were conducted between December 8, 2005 and April 27, 2006. The major components of the RA activities conducted at Site L4 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the October 1998 ROD, the Final Phase 1 Remedial Design/Remedial Action Work Plan (MWH, 1999a) and the Final Remedial Action Work Plan for Remediation of Soils at Operable Unit - (L4 Landfill) (MKM, 2005a). During RA activities, approximately 18,405 CY of landfill material were excavated from Site L4 and transported to the Prairie View RDF for disposal.

Remedial action activities included confirmation sampling at the site consistent with the October 1998 ROD, the Final Phase 1 Remedial Design/Remedial Action Work Plan (MWH, 1999a), and the Site L4 Remedial Action Work Plan (MKM, 2005a). Confirmation sampling results show that concentration of all analytes from all samples were less than the final recreational RGs established in the October 1998. All visible landfill material was removed and the excavation limits were inspected and approved by the USACE representative.

Treated soil from the Site M4 BTF was utilized as a source of backfill material. Following approval by the USEPA, IEPA, USACE, approximately 18,465 CY of treated SRU1 soil was used as backfill material in the Site L4 excavation. Excavations were backfilled and regraded to prevent ponding and promote proper drainage.

Equipment utilized during RA activities at Site L4 was decontaminated, following completion of excavation activities, and moved to other sites at JOAAP with active excavation activities. Final demobilization from the site was completed on March 1, 2006. Seeding, mulching, and fertilizing were performed in accordance with the Site L4 Remedial Action Work Plan (MKM, 2005a) following demobilization. Hydroseeding was completed on April 27, 2006 and the silt fence was removed on November 28, 2006.


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The selected remedy has successfully functioned to remove SRU6 soils above RGs from Site L4. The RAOs set forth in the October 1998 ROD have been satisfied for the site. Closure of Site L4 is documented in the Final L4 Remedial Action Completion Report (MKM, August 2007).

4.2.6.3 Site M1 Remedial action activities were conducted in accordance with the October 1998 ROD, the Phase 1 – Remedial Design/Remedial Action Work Plan (MWH, 1999a) and the Final Remedial Action Work Plan for Remediation of Soils Operable Unit 6, M1 Landfill (MKM, April 2006). Remedial action activities were conducted at Sites M1 to satisfy the final RGs for SRU6 soils and RAOs stated in the October 1998 ROD.

The major components of the selected remedy for SRU6 soils at Site M1 included:


Land use restrictions will be developed separately from the October 1998 ROD by the Army, USEPA, and IEPA. These land use restrictions will run with the land until removed by mutual agreement of the Army, USEPA, IEPA, and IEPA. Land designated for the USDA (Site M1) cannot be used for industrial or residential use.

MWH conducted an inspection for the temporary geosynthetic liner on November 10, 1998 to assess the condition of the covering materials. At the time, it was noted that approximately 40 to 50 percent of the existing liner had been removed by high winds. Following direction from USACE, MWH prepared preliminary estimates of the cost to either repair or replace the existing covering system. Following an inspection conducted on December 17, 1998, it was decided that the existing covering system could not be cost effectively repaired and a replacement covering system should be installed.

Additional field investigation was performed by MWH in February 1999 in conjunction with the preparation of the RD/RAWP. Based on their findings, none of the RGs have been exceeded by the red water ash and the red water ash is not a RCRA characteristic hazardous waste, as defined by 40 CFR 261.

Covering system interim O&M activities were conducted from April 27 to July 1, 1999 which included removing and disposing of the existing High Density Polyethylene (HDPE) geomembrane cover materials; regrading and compacting the soil/ash subgrade; installing a new

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geomembrane cover system; installing a covering anchor system; and completing associated work activities. Construction activities for the interim cover were documented in the Draft Final Construction Completion Report and Operation and Maintenance Plan, Site M1 Interim Cap (Montgomery Watson, November 1999).

Additional field investigation was performed by MWH in February 1999 in conjunction with the preparation of the RD/RAWP. Based on their findings, none of the RGs have been exceeded by the red water ash and the red water ash is not a RCRA characteristic hazardous waste, as defined by 40 CFR 261.

RA activities at Site M1 have been completed however; the Final Closure Report was not available during the writing of this review.

4.2.6.4 Site M9 Remedial action activities at Site M9 were conducted between November 15, 2005 and April 28, 2006. The major components of the RA activities conducted at Site M9 included:


USEPA and IEPA have verified that all RA activities were conducted in accordance with the October 1998 ROD, the Phase 1 – Remedial Design/Remedial Action Work Plan (MWH, 1999a) and the Final M9 Remedial Action Work Plan for Remediation of Soils at Operable Unit 6 M9 Northern Ash Pile (MKM, 2005a). During RA activities, approximately 50,535 CY of landfill material were excavated from site M9 and transported to the Prairie View RDF for disposal.

One surface water sample (M9-DOJ-031406) collected on March 14, 2006 exceeded the Illinois Surface Water Quality Standard for sulfate of 500 milligrams per liter (mg/L) with a result of 2,500 mg/L. A Corrective Action Technical Memorandum was issued on August 3, 2006 to address the exceedance at Site M9. A copy of the Corrective Action Technical Memorandum is located in Appendix C of the Final M9 Remedial Action Completion Report (MKM, September 2007).

Remedial action activities included confirmation sampling at the site consistent with the October 1998 ROD, the Phase 1 – Remedial Design/Remedial Action Work Plan (MWH, 1999a), and the Final M9 - Remedial Design/ Remedial Action Work Plan (MKM, 2005a).

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A composite sample was collected from the truck staging and turn around area following RA activities. The results of the post-RA composite sample did not exceed the current background conditions in the vicinity of the Site M9. Based on visual inspection by MKM and USACE representatives, excavation and disposal of red water ash was completed on February 24, 2006.

Backfilling activities were conducted between February 27, 2006 and April 18, 2006. Backfill was comprised of the stripped clean cover soils that were stockpiled onsite and treated soil from the Site M4 BTF. Approximately 34,850 CY of treated soil was used as backfill material in the Site M9 excavation in addition to the clean cover soils that were reapplied to the excavation as backfill. The excavation was backfilled and regarded to prevent ponding and promote proper drainage.

Equipment utilized during RA activities at Site M9 was decontaminated, following completion of excavation activities, and moved to other sites at JOAAP with active excavation activities. Final demobilization from the site was completed on April 27, 2006. Seeding, mulching, and fertilizing were performed in accordance with the Final M9 - Remedial Design/Remedial Action Work Plan (MKM, 2005a) following demobilization. Hydroseeding was completed on April 28, 2006.

The selected remedy has successfully functioned to remove SRU6 soils above RGs from Site M9. The RAOs set forth in the October 1998 ROD have been satisfied for the site. Closure of Site M9 is documented in the Final M9 Remedial Action Completion Report (MKM, September 2007).

4.2.6.5 Site M11 Remedial action activities at site M11 were conducted between July 16, 2006 and December 21, 2007. The major components of the RA activities conducted at Site M11 included:

� Mobilization � Site Preparation � Storm Water Management � Soil Excavation � Soil Transportation and Disposal � Sampling and Analysis � Cap Construction � Decontamination � Site Restoration � Demobilization

RA activities were conducted in accordance with the October 1998 ROD and the Final M11 Work Plan for Soil Remediation Unit 6 (MKM, 2007). During RA activities, approximately 67,695 CY of landfill material was excavated from the M11 South debris area and approximately 41,755 CY of landfill material was excavated from the M11 Northeastern debris area and consolidated to the M11 North Landfill.

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Remedial action activities included confirmation sampling at the site consistent with the October 1998 ROD. Confirmation sampling results show that concentration of all analytes from all samples were less than the final recreational RGs established in the October 1998.

Treated soil from the Site M4 BTF was utilized as a source of backfill material. Following approval of the confirmatory sampling results by the USEPA, IEPA, USACE, approximately 28,870 CY of treated SRU1 soil was used as backfill material in the M11 Northeastern excavation area and 38,672 CY of treated SRU1 soil was used as backfill material in the M11 South excavation area. Excavations were backfilled and regraded to prevent ponding and promote proper drainage.

Construction of the RCRA Subtitle C landfill cap began in October 2006. The M11 Landfill cap covers approximately 7.8 acres and consists of a general fill grading layer, a granular grading layer, a geosynthetic clay layer, a geomembrane, geonet geocomposite, a root zone, topsoil, gas vents, and rip-rap. Revegetation of the cap was completed in December 2007.

Equipment utilized during RA activities at Site M11 was decontaminated, following completion of excavation activities. Hydroseeding, mulching, and fertilizing were performed in accordance with the Final M11 RAWP (MKM, 2007). Final demobilization from the site was completed on December 21, 2007

In August 2008 a 5-wire barbed fence was installed around the perimeter of the M11 Landfill Cap to control unauthorized access to the site. Signage, warning of restricted access, was placed on the fence every 150 feet.

The Site M11 landfill area requires 30 years of long-term maintenance as defined in 35 IAC 724.217. The Site M11 groundwater monitoring program will be conducted in accordance with 35 IAC724.200(c) - Corrective Action Program as specified in the Record of Decision for the Soil and Groundwater Operable Units on the Manufacturing and Load-Assemble-Package Areas, National Priority List Sites (U.S. Army, 1998).

Land use restrictions will be developed separately from the October 1998 ROD by the Army, USEPA, and IEPA. These land use restrictions will run with the land until removed by mutual agreement of the Army, USEPA, and IEPA. Land designated for the USDA (Site M11) cannot be used for industrial or residential use.

RA activities conducted at Site M11 are described in the Draft Final M11 Remedy in Place Report (MWH, September 2008). RA activities at Site M11 have been completed however; the Final Closure Report has not been approved.

The selected remedy has successfully functioned to consolidate all SRU6 soils at Site M11 to the M11 North Landfill. The RAOs set forth in the October 1998 ROD have been satisfied for the site. Successful implementation of the remedy is documented in the Draft Final M11 Remedy in Place Report (MWH, September 2008).

94


4.2.6.6 Site M13 Remedial action activities were conducted in accordance with the Final Remedial Action Work Plan for the Remediation of Soils Operable Unit 6, M13 Landfill (MKM, September 2007). Remedial action activities were conducted at Site M13 to satisfy the final RGs for SRU6 soils and RAOs stated in the October 1998 ROD.

The major components of the selected remedy for SRU6 soils at Site M13 included:

� Capping � Institutional Controls

Land use restrictions will be developed separately from the October 1998 ROD by the Army, USEPA, and IEPA. These land use restrictions will run with the land until removed by mutual agreement of the Army, USEPA, and IEPA. Land designated for the USDA (Site M13) cannot be used for industrial or residential use.

RA activities were conducted at Site M13 to address SRU6 soils by constructing a RCRA Subtitle D landfill cap at the site.

RA activities at Site M13 have been completed however; the Final Closure Report has not been approved as of the writing of this review.

4.2.7 SRU7 Soils

4.2.7.1 Site M8

During liquidation activities at the site, prior to the transfer of property to the State of Illinois, removal activities were conducted to remove sulfur from surficial soils. On August 10, 2000, the site was transferred to the State of Illinois for inclusion into an industrial park facility. Following the land transfer, the State of Illinois sold the site to CenterPoint Properties. Subsequent site activities have included the construction of an intermodal rail facility currently operated by BNSF. According to the FOST, February 1999, there were no exceedances of soil industrial remediation goals at Site M8. This site is closed. CenterPoint Properties submits certification of compliance for implementation of institutional controls, specified in the property deed, to the Army on an annual basis.

4.2.8 Site M4 Bioremediation Facility Bioremediation was the selected remedy for the treatment of a large percentage of the explosives-contaminated soils at JOAAP. A portion of Site M4 was selected as the site to construct the Bioremediation Treatment Facility (BTF). Construction of the BTF began in May 1999, and operations (stockpiling of soil) started in July 1999. Site M4 operations remained active through 2007.

95


Bioremediation was the selected remedy for treatment of SRU1 and SRU3 soils at JOAAP. Bioremediation has proven to be an effective means to reduce contaminant concentrations in explosives-contaminated soil to levels below RGs. In general, composting and bioslurry processes have received the widest acceptance for treatment of explosives such as TNT, HMX, RDX, and DNT. Economic considerations and ease of implementation of this technology has warranted its implementation at JOAAP and has been critical to the overall success of project operations.

Tetryl soils were from SRU1 and SRU3 were also treated at the BTF. The tetryl soils were stockpiled and segregated for treatment.

Remedial design of the BTF was conducted between March 1999 and July 1999. Construction activities were completed between May 1999 and July 1999, and included construction of the following components:

� Decontamination building � Amendment storage building � Blending and Processing Area � Storm water Retention Basin/Process Water Reservoir (SB1 and SB2) � Bioremediation Buildings � Treatment Material Storage Area � Internal Roads � Office/Laboratory

In an effort to further refine the windrow composting process, a field demonstration was performed in August/September 1999. Objectives of the field demonstration included:

� Re-confirm the effectiveness of the composting operation in meeting the RGs � Refine composting process performance � Refine field-monitoring methods � Collect physical characteristic data of treated compost � Refine optimum amendment blend � Refine optimum soil loading rate

A total of nine windrows, each approximately 36 feet long, 16 feet wide, and 6 feet high were constructed as part of the field demonstration. To evaluate different composting methods, several variables were selected as test parameters to evaluate their impact on the compost process performance. These variables included:

� Amendment recipe � Soil loading rate � Amendment pre-blending � Turning frequency

96

�


Following the field demonstration, it was determined that the amendment blending ratio of 52% stable bedding, 30% wood chips, and 18% corn processing waste provided the most advantageous environment for microbial activity to flourish when mixed with explosives-contaminated soil. This amendment blend proved to be most effective when pre-blended and mixed at a ratio of 70 to 30 amendments to soil (by volume). The amendments selected for use in composting soils at JOAAP include corn-processing waste, wood chip mulch, and stable bedding. Factors evaluated in selecting the amendments included nutrient content (C:N ratio), moisture content, structure, porosity, texture, and availability.

Prior to amendment addition, pretreatment sampling was conducted to collect sufficient data to consistently quantify explosive concentrations in the soil prepared for treatment.

Post-treatment sampling was conducted in accordance with the SAP Addendum for Bioremediation Post Treatment Sampling (Montgomery Watson, July 2000), which describes the protocol to confirm that treated soils do not exceed RGs. Post-treatment sampling for explosives was performed on SRU1 soils, and explosives and lead on SRU3 soils, to verify that explosives (and lead) concentrations in each windrow were reduced to below the RGs. Each windrow was managed as a single remediation unit. At such time that field measurements indicated adequate biotreatment, post-treatment sampling was conducted across the entire windrow. Because the windrows were constructed from pre-segregated material (i.e., segregated by SRU, contaminant type, and site), it was reasonable to consider that each windrow would contain relatively consistent material following treatment. This was further supported by the rigorous mechanical mixing that took place as part of windrow composting where soil was repeatedly augered, intermixed, and redistributed in freshly formed rows. Therefore, composite sampling at several stations within each windrow was the selected method for post-treatment sample collection.

Composite samples were collected from 12 windrow stations, randomly selected along the entire length of each windrow. In May 2002, the Army proposed a reduction of post treatment samples from 12 to 8 samples per windrow, in an effort to reduce costs. The proposal was accepted by both the IEPA and USEPA and was implemented by sampling personnel at the Site M4 BTF. Sampling stations were identified using the structural steel ribs of each treatment building as station markers. The building ribs were numbered from 1 (at the north) to 17 (at the south), and sample identification and collection locations were based on that numbering scheme to provide concise, repeatable, sample station locations. Post-treatment sample results were compared to the RGs to evaluate the effectiveness of the treatment process.

Several supplemental sampling and/or analysis activities were completed during treatment to provide better characterization and assure proper treatment. These included:

� Sample analysis for TCLP 2,4-DNT when total 2,4-DNT concentrations are less than the RG (8.4 mg/kg), but greater than 2.0 mg/kg. This ensures no characteristically hazardous 2,4-DNT remains.

� Analysis of samples from two randomly selected (SRU1) windrow stations for total lead to verify that lead impacted soils were properly delineated in the field and segregated into SRU3 stockpiles.

97


The analytical results presented were based on the entire sample, which includes soil and amendments. However, based on the following qualitative description, it was determined that the dilution effects were negligible. The weight ratio of soils to amendment was 1:1. During the bioremediation process, a significant amount of the amendment was consumed. At the laboratory, rocks, wood chips and straw were removed to prepare the sample prior to the extraction process. As a result of these events, the residual sample that was used for analysis was primarily soil with a small amount of corn waste and horse manure.

A windrow (or windrow station) was removed from the treatment building to the treated soil stockpile when analytical results indicated all RGs had been achieved.

A windrow station failing to meet RGs was isolated from “clean” stations and resampled or incorporated into the subsequent windrow for additional treatment. Windrow stations were isolated half the distance north and south to the next “clean” sample station. When a station not sampled was isolated due to adjacent station failure, that non-sampled station was managed in the same manner as the failing station.

In addition SRU1 and SRU3 soils, SRU5 soils were also treated at the Site M4 BTF. In the June 2004 ROD, Bioremediation was the selected remedy for treatment of SRU5 soils at Site L1 and Site L5. The treatment process for SRU5 soils was consistent with the treatment process for SRU1 and SRU3 soils.

The treatment of contaminated soil at the Site M4 BTF was complete in 2007. The Site M4 BTF was demolished following the competition soil treatment.

A yearly summary for soil treated at the Site M4 BTF is presented in Table 9.

Table 9: Summary of Soil Treated at the Site M4 Bioremediation Treatment Facility FY

2000

Tons of Soil SRU

1

Site

M6

Primary COC

TNT/DNT Treated (dry)

12,151 2001 35,660 1 M6 TNT/DNT 2001 4,500 1 M7 TNT 2002 15,040 1 M7 TNT 2002 21,616 1 M6 TNT/DNT 2003 27,850 1 M6 TNT/DNT 2003 2,585 3 M6 TNT/DNT 2003 6,367 3 M5 Tetryl 2004 23,349 1 M6 DNT 2004 16,651 3 M6 TNT 2005 46,374 3 M6 TNT

2006* 43,761 1 Not specified Not specified 2006* 3,447 5 Not specified Not specified 2007* 14,650 1 Not specified Not specified 2007* 117 1 M11 DNT

*Note this information is based on communication with USACE. Documents were not available at the time of this review.

98


Table 10 summarizes the Bioremediation Reports which contain the pre-treatment and posttreatment sample concentrations since the start of operations. The FY2003 through FY2007 Bioremediation Reports were not available for review during the writing of this document.

Table 10: Site M4 BTF Bioremediation Reports

Year Report Submittal Date 2000 Final FY 2000 Bioremediation Report, Bioremediation Facility November 2001 2001 Final FY 2001 Bioremediation Report, Bioremediation Facility January 2004 2002 Final FY 2002 Bioremediation Report, Bioremediation Facility January 2004 2003 Final FY 2003 Bioremediation Report, Bioremediation Facility May 2007 2004 Final FY 2004 Bioremediation Report, Bioremediation Facility May 2007 2005 Final FY 2005 Bioremediation Report, Bioremediation Facility June 2009* 2006 Final FY 2006 Bioremediation Report, Bioremediation Facility June 2009* 2007 Final FY 2007 Bioremediation Report, Bioremediation Facility June 2009*

*Note this information is based on communication with USACE. Documents were not available at the time of this review.

4.2.9 Implemented Institutional Controls and Access Controls

A summary of implemented institutional and access controls for RA sites is included as Table 11.

Perimeter fencing surrounds the LAP area prohibiting unauthorized access.

Site inspections were conducted to assess the current conditions of the sites. Copies of the site inspection observation forms are located in Attachment 6. Deficiencies and recommendations noted during the site inspections will be discussed in Section 8.0 and Section 9.0 of this report.

4.3 System Operation/Operation and Maintenance

4.3.1 SRU1 Soils

4.3.1.1 Sites L1, L2, L7, L8, L9, L10, L14, L16, M2, M3, M5, M6, and M7 Maintenance costs are not anticipated at Sites L1, L2, L7, L8, L9, L10, L14, L16, M2, M3, M5, M6, and M7. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.

99

Aug

ust 2

009

Fina

l – S

econ

d Fi

ve-Y

ear R

evie

w R

epor

t W

912Q

R-0

8-D

-000

9/00

02

JOA

AP

– So

il O

pera

ting

Uni

t

Tab

le 1

1: S

umm

ary

of Im

plem

ente

d In

stitu

tiona

l and

Acc

ess C

ontr

ols

Site

L1

Acc

ess C

ontr

ols

Inst

itutio

nal C

ontr

ols

SRU

Des

igna

tion

Futu

re

Cur

rent

Dee

d or

Su

bmits

Ann

ual

Fenc

ing

SRU

1, S

RU

4, S

RU

5 Y

es

Lan

d U

se

Ow

ner

Lan

d U

se

Cer

tific

atio

n of

R

estr

ictio

ns

Com

plia

nce

Yes

N

o Pr

airie

U

.S. A

rmy

L2

SRU

1, S

RU

2 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L3

SRU

2, S

RU

3, S

RU

6 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L4

SRU

6 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L5

SRU

2, S

RU

4, S

RU

5 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L6

N/A

(4)

Yes

Y

es

No

WC

LF/In

dust

rial

WC

LF

L7

SRU

1, S

RU

4 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L8

SRU

1, S

RU

4 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L9

SRU

1, S

RU

4 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L10

SRU

1, S

RU

4 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

L11

SRU

2 Y

es

Yes

N

o In

dust

rial

Inte

rnat

iona

l Uni

on o

f O

pera

ting

Engi

neer

s L1

4 SR

U1

Yes

Y

es

No

Prai

rie

U.S

. Arm

y L1

6 SR

U1

Yes

Y

es

No

Indu

stria

l JA

DA

L1

7 SR

U4

Yes

Y

es

No

Indu

stria

l JA

DA

L2

3A

SRU

2 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

M1

SRU

6 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

M2

SRU

1 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

M3

SRU

1, S

RU

2, S

RU

3 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

M4

SRU

2 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

M5

SRU

1, S

RU

3 Y

es

Yes

Y

es

Indu

stria

l El

woo

d In

term

odal

and

C

ente

rPoi

nt

M6

SRU

1, S

RU

3 Y

es

Yes

N

o In

dust

rial

U.S

. Arm

y M

7 SR

U1

Yes

Y

es

No

Indu

stria

l U

.S. A

rmy

M8

SRU

7 Y

es

Yes

Y

es

Indu

stria

l JA

DA

and

Elw

ood

Inte

rmod

al

100

Aug

ust 2

009

Fina

l – S

econ

d Fi

ve-Y

ear R

evie

w R

epor

t W

912Q

R-0

8-D

-000

9/00

02

JOA

AP

– So

il O

pera

ting

Uni

t

Site

M9

Acc

ess C

ontr

ols

Inst

itutio

nal C

ontr

ols

SRU

Des

igna

tion

Futu

re

Cur

rent

Dee

d or

Su

bmits

Ann

ual

Fenc

ing

SRU

6 Y

es

Lan

d U

se

Ow

ner

Lan

d U

se

Cer

tific

atio

n of

R

estr

ictio

ns

Com

plia

nce

Yes

N

o In

dust

rial

U.S

. Arm

y M

11

SRU

6 Y

es

Yes

N

o Pr

airie

U

.S. A

rmy

M12

SR

U2,

SR

U7

Yes

Y

es

No

Prai

rie

U.S

. Arm

y M

13

SRU

6 Y

es

Yes

Y

es

Indu

stria

l U

.S. A

rmy

M16

N

/A (4

) Y

es

Yes

Y

es

Indu

stria

l El

woo

d In

term

odal

1.

Per

imet

er fe

ncin

g su

rrou

nds t

he e

ntire

LA

P ar

ea to

pre

vent

una

utho

rized

acc

ess t

o th

e si

tes.

2. O

nly

prop

ertie

s tha

t hav

e be

en tr

ansf

erre

d by

dee

d, c

urre

ntly

hav

e ac

tive

deed

rest

rictio

ns. A

por

tion

of S

ite M

6 (S

ite M

6 N

orth

) has

bee

n tra

nsfe

rred

by

deed

and

cur

rent

ly h

as d

eed

rest

rictio

ns e

nfor

ced.

3.

A p

ortio

n of

Site

M13

has

bee

n tra

nsfe

rred

to th

e St

ate

of Il

linoi

s. Th

e pa

rcel

of l

and

on S

ite M

13 th

at h

as S

RU

6 so

ils, r

emai

ns u

ndev

elop

ed

and

undi

stur

bed.

4.

Rem

oval

act

ions

wer

e co

nduc

ted

at S

ites L

6 an

d M

16 p

rior t

o th

e O

ctob

er 1

998

RO

D d

esig

natio

n of

SR

Us o

r fin

al o

r int

erim

site

stat

us. S

ites

L6 a

nd M

16 w

ere

desi

gnat

ed a

s No

Furth

er A

ctio

n si

tes i

n th

e O

ctob

er 1

998

RO

D.

5. A

por

tion

of S

ite L

6 w

as tr

ansf

erre

d to

con

stru

ct th

e W

ill C

ount

y La

ndfil

l (W

CLF

). A

por

tion

of S

ite L

6 w

ill b

e tra

nsfe

rred

for i

ndus

trial

re

use.

101


4.3.2 SRU2 Soils

4.3.2.1 Sites L2, L11, L23A, M3, and M4 Maintenance costs are not anticipated at Sites L2, L11, L23A, and M3. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.

4.3.2.2 Sites L3 and L5 Maintenance at Sites L3 and L5 was limited to implementation of short-term O&M and erosion control measures. Erosion control maintenance and inspection activities were conducted following completion of RA activities.

4.3.3 SRU3 Soils

4.3.3.1 Sites L2, M3, M5, and M6 Maintenance costs are not anticipated at Sites L2, M3 M5, and M6. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.

4.3.3.2 Site L3 Maintenance at Site L3 was limited to implementation of short-term O&M and erosion control measures. Erosion control maintenance and inspection activities were conducted following completion of RA activities.

4.3.4 SRU4 Soils

4.3.4.1 Sites L1, L7, L8, L9, L10, and L17 Maintenance costs are not anticipated at Sites L1, L7, L8, L9, L10, and L17. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.


102


4.3.5 SRU5 Soils

4.3.5.1 Site L1 Maintenance costs are not anticipated at Site L1. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.


4.3.6 SRU6 Soils The Final O&M Plan (MKM, 2006) has been prepared for the sites included in SRU6 at the JOAAP and pertain to landfill sites L3, L4, M1, M9, M11, and M13. A new Long-term Monitoring Plan is in the process of being approved.

4.3.6.1 Sites L4, M1, and M9 Maintenance costs are not anticipated at Sites L4 and M9. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.

4.3.6.2 Sites L3, M11, and M13 O&M procedures and inspection activities will be limited to long term care and monitoring as identified in 35 IAC 724.217 for Sites L3 and M11, and 35 IAC 811.318 for Site M13. Long term care of the landfill caps will include quarterly inspections of the cap, vegetation, and drainage structures for the first five years and annual inspections an additional 25 years for Sites L3 and M11, and an additional 10 years for Site M13. The integrity of the cap will be maintained by repairing depressions due to settling and subsidence, and repairing eroded surfaces.

A site inspection of landfills L3, M11, and M13 was conducted by Toltest, Inc on October 16, 2008. In the Post-Closure Inspection report for Landfills L3, M11, and M13 dated December 17, 2008, areas of cap settling were reported at sites M11 and M13.

On December 30, 2008, a site inspection was performed by Michael Baker Jr., Inc. and Mark Freuh. According to the M11 and M13 Landfill Settlement Confirmation report dated January 5, 2009, both M11 and M13 cover systems appear intact and functioning within design and regulatory parameters. No obvious signs of settlement, subsidence or ponded water on the surface or landfill cover were observed during the site walk. Vegetation growth was well established except where previous vegetation repairs were conducted. Recommendations for

103


M11 and M13 were soil backfill and seed as necessary to eliminate minor surface erosion and the small surveyor hole noted at M13.

4.3.7 SRU7 Soils

4.3.7.1 Sites M8 and M12 Maintenance costs are not anticipated at Sites M8 and M12. Short-term maintenance at the time of construction completion was limited to maintenance of erosion control measures. Once sufficient vegetative growth was established at the site, monitoring of erosion control measures was discontinued.

4.3.8 No Further Action Sites

4.3.8.1 Sites L6 and M16 There is no long term O&M costs associated with the implementation of institutional controls at NFA sites.

4.3.9 Summary of Costs for Operation/Operation and Maintenance

Annual costs for system Operations/O&M for LTM in the SOU are presented in Table 12. Costs are associated with erosion control, inspections, and landfill capping activities.

Table 12: Annual System Operations/O&M Costs for the SOU

Year Total Cost 2005 $200,070 2006 $151,033 2007 $131,522 2008 Not available

4.4 Institutional Controls

The selected RGs and RAOs for JOAAP were designed to be protective of human and ecological receptors based on the intended land use, and were not intended for unlimited exposure and unrestricted use scenarios; therefore, institutional controls (ICs) were included as part of the remedy. ICs are non-engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to soil or groundwater that has not been remediated to levels which would allow for unlimited use or unrestricted exposure. ICs can also be used to protect the integrity of the remedy. Effective ICs are required to ensure the protectiveness of the remedy at JOAAP.

104


The ICs vary depending upon impacted media and the intended land use, but share at least one common objective; to limit the exposure of human and ecological receptors to hazardous substances, pollutants or contaminants remaining at the site above the levels that would allow for unlimited use or unrestricted exposure to soil or groundwater in order to avoid unacceptable risks. Compliance with ICs is required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure. Soil and groundwater have been remediated to levels which do not allow for unlimited use or unrestricted exposure; therefore, three primary land use categories, prairie/recreational, landfill, and commercial/industrial, have been designated for various areas of JOAAP. Each land use category is restricted by a different set of ICs. ,

ICs have been implemented over the entirety of all land areas which do not allow for unlimited use or unrestricted exposure at JOAAP that have been transferred by the U.S. Army; including Federal to Federal and Federal to State and County transfers. The ICs are evaluated in more detail in subsequent sections.

Graphical depictions of ICs referenced in subsequent sections are based on data derived from various sources and documents that are believed to be reliable and up to date, including deeds and the USDA FS Prairie Plan. The data used to depict the property ownership in the areas covered by ICs was derived from the Will County GIS web site. References to these various maps are provided in subsequent sections. Compliance with the ICs is documented semiannually by the O&M contractor during groundwater sampling activities and annually in letter or reports prepared by current or previous property owners bound by the terms of the ICs. Semiannual groundwater monitoring reports are submitted to USEPA and IEPA.

Based on the data reviewed for this Five Year Review the existing ICs are preventing exposure to soil and groundwater and are effective in maintaining the objectives/restrictions/performance standards in the short term and in the long term. Land use has changed in the restricted areas with development since execution of the ROD, but is consistent with the uses intended in the ROD, the Prairie Plan and the respective 2009 zoning maps for the Town of Elwood, the City of Wilmington, and Will County. Zoning and land use maps are presented in Attachment 9, Figures A9-4 through A9-8.

Most of the property to be conveyed by the U.S. Army in the MFG Area has already been conveyed. The remaining parcels to be transferred to non-Federal entities are already described in previous deeds which include ICs that are anticipated to be protective of human health and the environment when the remedy for soil has been completed and accepted as final; however, any parcel transferred with landfill (M13) will require additional ICs that prohibit interference with the landfill cap. Most of the property that will be transferred to the USDA FS will likely include similar ICs to those described in the Prairie Plan for M3 Areas; however, any parcel transferred with landfill (M11) will require additional ICs that prohibit interference with the landfill cap.

Most of the property to be conveyed by the U.S. Army in the LAP Area has already been conveyed. The remaining parcels will be Federal to Federal transfers and will likely include similar ICs to those described in the Prairie Plan for M3 Areas; however, any parcel transferred with landfill (L3) will require additional ICs that prohibit interference with the landfill cap.

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New developments are planned in the Deer Run Industrial Park in the MFG Area and in the Island City Area of the LAP Area. Planned land use in both areas is consistent with the long range development plans and the existing developments in these areas. It is anticipated that development of these areas will proceed when the Final Remedy for soil is complete, and as economic conditions dictate. The current and anticipated future land and resource uses are consistent with the exposure assumptions and risk calculations presented in the ROD. No unintended consequences have been reported or observed as a result of the ICs.

Further details regarding the ICs and recommendations to enhance documentation of compliance with the ICs to verify that they are being implemented correctly, are presented in the following sections.

4.4.1 ICs for Remediated Land Transferred to the USDA FS Due to the procedure for transfer of land from one Federal agency to another, formal deeds were not recorded for property that was transferred from the U.S. Army to the USDA Forest Service. However, Army conveyance documents including the Environmental Condition of Property (ECOP) and Letters of Assignment, included applicable land use restrictions. These restrictions were incorporated into the USDA Forest Service official land management plan for the site (The Prairie Plan). An amendment to the Prairie Plan (Amendment 1) prepared June 28, 2008 established a separate management area (MA 3) to provide direction for monitoring and reporting on land uses for remediated lands transferred from the U.S. Army. MA 3 lands have two designations which carry separate restrictions; Soil Restricted Areas (SRA) and Groundwater Management Zones (GMZ).

According to the amended Prairie Plan, SRAs are areas where soils contaminated with chemicals of concern have been remediated to the standards identified in the 2004 ROD or are areas where bio-remediated soils have been used as backfill. In either case, the sites in SRAs do not meet a residential standard (i.e. no picnic areas or campgrounds) and require land use constraints and tracking. GMZs are areas which have contaminated groundwater which is expected to attenuate naturally over time. Restrictions on groundwater use in the GMZs will be in place until monitoring indicates that water quality meets the standards identified in the 1998 ROD. MA3 land may not be suitable for any future land conveyances without consultation with the U.S. Army, Illinois EPA and USEPA and additional cleanup. MA3 land that is conveyed outside a governmental agency, land must be remediated to a residential standard, or conveyed with a deed restriction.

Approximately 1,028 acres of land were allotted to MA 3 with the amendment and have one or both of the SRA and GMZ designations. The Prairie Plan (as amended) includes requirements for the Forest Service to report to the U.S. Army, Illinois EPA and USEPA annually on the status of land use and groundwater restrictions as well as any land use proposals that would be, or were, affected by them. The location and extent and type of MA3 land is depicted in Attachment 9, Figure A9-2. The IC objectives, standards, and restrictions are fully described and clearly stated in the Prairie Plan. In addition to general restrictions preventing unrestricted exposure to soils which have not been remediated to levels that allow for unlimited access or unrestricted reuse, and preventing the development and use of the property for residential,

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schools, childcare or playgrounds, or industrial uses, the following additional restrictions for MA3 land are required by the Prairie Plan. Table 13 summarizes the Institutional Controls for land transferred to the USDA Forest Service.

1. SRA – Movement of soil from soil restriction areas (SRA) can only be moved within the same parcel, to another soil restriction area, or removed to a landfill permitted to accept restricted soils. Incidental soil movement, including but not limited to soil on equipment, plant salvage and soil sampling, is not subject to this restriction.

2. GMZ – Prohibit installation of groundwater production wells, or any other activities that could cause migration of contaminated groundwater, within the boundaries of groundwater management zones (GMZ) defined by the U.S. Army.

3. GMZ – If groundwater management zones are reduced or eliminated as a result of Army monitoring, the parcel cleared by the U.S. Army will revert to MA 1 – Prairie Ecosystem Restoration, without need of an amendment.

4. In areas that are comprised of more than one component of Management Area 3 (i.e. SRA and GMZ in the same area), applicable standards and guidelines will be followed for all component areas.

5. Report on condition of Management Area 3 lands annually in the Monitoring and Evaluation (M&E) Report and send M&E Report to the USEPA – Region 5, Illinois EPA and the U.S. Army

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Table 13 - Institutional Controls Summary For Land Transferred to USDA Forest Service

Media, Engineered Controls, & Areas that Do Not Support UU/UE Based on Current Conditions.

IC Objective Title of Institutional Control Instrument Implemented (note if planned)

� Restrict exposure to soils Soil – Land and Resource The area of restricted land use is which have not been Management Plan (Prairie Plan)

remediated to levels that identified in Attachment 9, Figure A9 Amendment #1 – Establishment allow for unlimited 1. of Management Area 3 access or unrestricted and Designation of Utilityuse Corridors into MA 2

� Prevent development for USDA Forest Service residential, schools, Midewin National Tallgrasschildcare, playgrounds, Prairieor industrial uses Wilmington, Will County, � No camping Illinois, June 26 2008 � Restrict soil movement.

Groundwater – � Prohibit installation of The areas designated as Groundwater groundwater production

wells, or any other Management Zones (GMZs) are activities that could identified in Attachment 9, Figure A9cause migration of 1. contaminated groundwater, within the boundaries of groundwater management zones (GMZ) defined by the U.S. Army.

� Maintain the integrity of groundwater or monitoring wells

Remedy Components

� Fulfill the annual tracking and reporting requirements to the U.S. Army, USEPA, and Illinois EPA

4.4.1.1 Adherence to ICs - USDA FS MA3 Land Land use restricted property was transferred to USDA in September 2005. The Forest Service Annual Monitoring and Evaluation Report for the following Fiscal Year (FY2007) restated the objectives of the restrictions and reported that no soil or groundwater disturbances occurred on land use restricted property. In addition, the Forest Service was proactive in amending the Prairie Plan to facilitate better tracking and management of the land use by designating a new Management Area for those lands with restrictions. The Prairie Plan and updates or amendments are provided to the U.S. Army, the USEPA and IEPA.

No activities were observed that would have violated the ICs during the site inspection.

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4.4.2 ICs for Land Transferred to the State (JADA) The ICs required for property conveyed from the U.S. Army to the State of Illinois (Joliet Arsenal Redevelopment Authority [JADA]) have been implemented as Land Use Restrictions and Covenants and Groundwater Restrictions and Covenants recorded on the deeds. This information is in addition to detailed descriptions of the environmental condition of the property.

Two quit claim deeds have been conveyed from the U.S. Army to JADA. A Memorandum of Agreement (MOA) included with the deeds, or included by reference, details requirements for compliance, and enforcement, and annual reporting requirements associated with the ICs. Legal descriptions and parcel and tract maps annotated with special groundwater restriction areas are also included as exhibits to the individual deeds. Copies of these documents are included in Attachment 9, and are described in chronological order as reference documents 1, 3, 4 and 5. A figure depicting the transferred areas color-coded and annotated with the appropriate deed reference document information is presented as Attachment 9, Figure A9-2.

The Land Use Restrictions and Covenants and Groundwater Restrictions and Covenants recorded on all of the deeds granted to JADA are generally the same. With limited exceptions as detailed in the deeds, the deeds generally state that the land shall be used for commercial and industrial parks and shall not be used for residential, educational, child or adult care, landfill, quarry, incineration, or concrete or asphalt batching purposes. Additionally, existing or future groundwater monitoring well shall not be used, moved, accessed, modified, removed, disturbed, close, abandoned, or otherwise harmed or destroyed. The IC objectives, standards, and restrictions are fully described and clearly stated in the deeds and MOA.

The deeds generally state that restrictions are necessary to ensure the protection of human health and the environment, and that the covenants that the restrictions therein shall run with the land and shall be binding upon the Grantee, its successors and assigns, future owners, heirs, and executors. The deeds also require that the land use restrictions and covenants be included in all subsequent lease, transfer, or conveyance documents for all or any part of the deeded tracts. Further, the deed states that failure to include the land use restrictions and covenants in all subsequent lease, transfer, or conveyance documents shall not abrogate the status of these restrictions and covenants as binding upon Grantee, its successors and assigns, future owners, heirs, and executors.

The deeds generally state that the Grantee (JADA) shall not knowingly or negligently undertake or allow any activity on or use of the deeded property that would violate the land use restrictions and covenants, and that the land use restrictions and covenants are enforceable by the U.S. Army.

Groundwater Restrictions for land within the GMZ generally state that JADA and future owners shall not use the groundwater above the Maquoketa confining bed for potable purposes and shall not cause any increase the volume or area of the contaminated groundwater, damage the confining layers, or create pathways of exposure to human or ecological receptors from the contaminated groundwater. All laws and regulations that are applicable to the safe and proper management, discharge, disposal, or treatment of any shallow groundwater encountered shall also be complied with.

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Additional restrictions applicable to specific parcels of land included in the deeds generally state that JADA or future owners shall not use the contaminated groundwater; and shall not drill, construct, pump, or use groundwater supply wells. Table 14 summarizes the Institutional Controls for land transferred to JADA.

Table 14 - Institutional Controls Summary For Land Transferred to JADA



Soil – The area of land restricted to commercial industrial cleanup use is identified in Attachment 9, Figure A9-2.

� Prohibit residential, educational, child or adult care use

Restrictive Covenant recorded in the following documents at the Will County Recorder’s Office:

� Document Number 20000086264 8/9/2000

� Document Number 200402130025145 3/15/2002

� Document Number 200504190064066 3/25/2005

Groundwater – The areas designated as Groundwater Management Zones and Groundwater Restriction Areas are identified in Attachment 9, Figure A9-2.

� Prohibit potable use of contaminated water

� Prohibit activities that could influence flow or damage confining layers

� Require proper management or disposal of contaminated water

� Prohibit ground water supply wells and any use of contaminated groundwater in the Groundwater Restriction Areas

Remedy Components � Prohibit Interference

with Remedy Components- do not damage monitor wells.

� Permit unrestricted Army access for remediation, monitoring, operation and maintenance

� No landfills, quarries, concrete or asphalt batching, or incineration.

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4.4.2.1 Adherence to ICs – Proper ty Conveyed to JADA With the exception of the Will County Landfill Parcel and Federal to Federal transfers, all other property transfers have been conveyed to JADA (Refer to Reference Documents 1,3,4 and 5 in Attachment 9). The initial deeds all include the ICs described above.

The majority of the property transferred to JADA in the MFG Area was conveyed by deed or by assignment to CenterPoint Intermodal. LLC (CPI) and CenterPoint Realty Services Corporation (CRSC), as part of the Deer Run Industrial Park. Although much of the land conveyed to CenterPoint has been subsequently conveyed to other entities, CenterPoint has retained the obligation for annual reporting of adherence to ICs contained in the MOA included in the initial deed. Current property ownership is depicted on a figure and the inset table, included as Attachment 9, Figure A9-3. In accordance with the documents that transferred industrial property with restrictions and covenants, CenterPoint has submitted annual letter reports to the U.S. Army attesting that no violations of same have occurred for every year except for 2008. Copies of the most recent reports are presented in Attachment 9 to demonstrate that the reports are received. These reports are copied to USEPA and IEPA. However, the letter reports do not make it clear whether the reports cover the entire extent of the areas conveyed from JADA to CenterPoint and it is not apparent in the conveyance documents reviewed whether the reporting obligations for property in the Deer Run Industrial Park conveyed by CenterPoint have changed. No activities were observed that would have violated the ICs during the site inspection.

A significant amount of the property transferred to JADA in the LAP Area has been subsequently conveyed to others including the International Union of Operating Engineers, Prairie Craftsman, LLC, and Prologis Logistics Services, Inc. This area of JOAAP is referred to as the Island City Development. Current property ownership is depicted on a figure and the inset table, included as Attachment 9, Figure A9-3. To date, none of the required annual letter reports required for these properties have been submitted. No activities were observed that would have violated the ICs during the site inspection.

4.4.3 ICs for Land Transferred to Will County The ICs required for property conveyed from the U.S. Army to Will County have been implemented as Land Use Restrictions and Covenants and Groundwater Restrictions and Covenants recorded on the deeds. This information is in addition to detailed descriptions of the environmental condition of the property.

One quit claim deed was conveyed from the U.S. Army to Will County. Legal descriptions and parcel and tract maps annotated with special groundwater restriction areas are also included as exhibits to the deed. A copy of the deed is included in Attachment 9, reference document 2). A figure depicting the transferred area color-coded and annotated with the appropriate deed reference document information is presented as Attachment 9, Figure A9-2.

The Land Use Restrictions and Covenants and Groundwater Restrictions and Covenants recorded on the deed granted to Will County generally state that the property may only be developed and utilized for landfill purposes and prohibits the development of the property for residential purposes and prohibits the use of groundwater within the glacial drift and Silurian

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dolomite aquifer and above the Maquoketa confining bed for human consumption. The deed restrictions generally state that Will County and future owners shall not undertake or allow any activity on or use of the Property that would violate the land use and groundwater use restrictions contained herein. The IC objectives, standards, and restrictions are fully described and clearly stated in the deed. The deed requires that the restrictions be binding on the Will County, its representatives, agents, contractors, successors and assigns, future owners, heirs and executors, and shall be included in all subsequent deeds, leases, transfer or conveyance documents and shall run with the land. Table 15 summarizes the Institutional Controls for land transferred to Will County.

Table 15 - Institutional Controls Summary For Land Transferred to Will County



Soil – The area of land restricted to commercial industrial cleanup use is identified in Attachment 9, Figure A9-2.

� Prohibit residential, educational, child or adult care use

Restrictive Covenant recorded in the following document at the Will County Recorder’s Office:

Document Number 200204120063838 4/12/2002

Groundwater – The areas designated as Groundwater Management Zones and Groundwater Restriction Areas are identified in Attachment 9, Figure A9-2.

� Prohibit potable use of contaminated water

� Prohibit activities that could influence flow or damage confining layers

� Require proper management or disposal of contaminated water

� Prohibit ground water supply wells and any use of contaminated groundwater in the Groundwater Restriction Areas

Remedy Components � Prohibit Interference

with Remedy Components- do not damage monitor wells.

� Permit unrestricted Army access for remediation, monitoring, operation and maintenance

� No landfills, quarries, concrete or asphalt batching, or incineration.

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4.4.3.1 Adherence to ICs - Will County Landfill There is no requirement for annual reporting included or referenced in the deed granted to Will County. Mr. Dean Olsen, Will County Waste Services, was interviewed during our site visit and indicated that there have been no changes or concerns regarding ICs or access controls at the site. The site is used only for landfill operations. The site is secured at night at both the Prairie View Lane entrance and the Main landfill entrance. All secondary access gates are padlocked when not in use, and site inspections are conducted on a regular basis to verify that they remain locked. There is limited access to the forest service, and there is no public access. No activities were observed that would have violated the ICs during the site inspection.

4.4.4 Summary of ICs for Soil Sites A robust set of ICs have been designed and implemented for all transferred properties that are no longer under the direct control of the U.S. Army. These ICs are protective of human health and the environment and protect the integrity of the remedy. Similar effective ICs are likely to be employed on subsequent property transfers as soil remediation is completed at the remaining sites although some sites including L3, M11, and M13 will require additional ICs that prohibit interference with the landfill caps.

Adherence to the ICs for land transferred to the USDA FS is very well documented. Adherence to the ICs for land transferred to non-Federal entities is not well documented.

For those properties in the MFG Area that were transferred from JADA to CenterPoint, the responsibility for submission of annual reports was assigned to CenterPoint and was documented by CenterPoint for all years up to 2007. However; it is not clear whether the annual reports submitted by CenterPoint include properties that were transferred from CenterPoint to other entities. According to the U.S. Army, Pre-Transfer notification and copies of related deeds and/or leases have not been provided to the U.S. Army, IEPA and USEPA as required in the initial deeds. Additionally, no written notice has been provided to the U.S. Army with respect to the assignment of the duties and obligations imposed by the MOA from CenterPoint to subsequent property owners, and no written concurrence has been provided by the U.S. Army. Therefore, it appears that the responsibility for reporting and other the duties and obligations imposed by the MOA for the property described above remains with CenterPoint at this point in time. The Will County Property Appraiser’s GIS system indicates that one 13-acre parcel in the MFG Area is owned by JADA. No annual reports have been received by the Army for the JADA-owned property in the MFG Area.

No annual reports have been received by the Army for the property currently and formerly owned by JADA in the LAP Area. No written notice has been provided to the U.S. Army with respect to the assignment of the duties and obligations imposed by the MOA from JADA to subsequent property owners, and no written concurrence has been provided by the U.S. Army. Therefore, it appears that the responsibility for reporting and other the duties and obligations imposed by the MOA for the referenced property remains with JADA at this point in time.

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There is no requirement for annual reporting included or referenced in the deed granted to Will County. Information obtained during the site visit for the Five Year Review indicates that Will County is familiar with, and in compliance with the requirements of the ICs.

4.4.5 Recommendations to Enhance Implementation of ICs Adherence to the ICs for land transferred to the USDA FS is very well documented and is updated annually in the Prairie Plan. The Prairie Plan identifies the areas that are under restriction, the objectives of the ICs, and the mechanisms required to achieve them. One recommendation to enhance the level of assurance and documentation that the ICs are properly implemented is to annually follow-up on the Prairie Plan with a short meeting or teleconference with minutes to verify and document that the ICs are fully understood. Consideration should also be given as to whether use of the State’s one-call system can be used enhance long-term protectiveness of the remedy.

It is recommended that a clear understanding of current roles and responsibilities with respect to monitoring, reporting, and enforcement of compliance with the ICs be developed for property that was transferred to non-Federal entities. This could be accomplished in a systematic manner, starting with JADA and CenterPoint.

JADA and CenterPoint should be informed of the U.S. Army’s understanding of their current responsibilities as established in the initial deeds and MOA, and should be asked to provide a letter concurring with the U.S. Army’s understanding or provide additional information for clarification if they do not concur with the U.S. Army’s understanding. At the same time, or subsequently, all other property owners of record in areas subject to ICs should be provided with a notification to ensure and document that they have been made aware of the environmental condition of property, ICs, and of the duties and obligations imposed by the MOA.

After it has been determined which entities are responsible for reporting for each property in areas subject to ICs, notification should be sent to each responsible entity reminding them of the deed restrictions duties and obligations. The notification should request that they provide a letter or report summarizing the current land use, any changes in land use during the previous year, any changes in land use during the previous year, any activities or excavations which disturbed the ground or groundwater, and any uses of groundwater. The letter or report should also summarize any anticipated changes in land use, property ownership, or any activities or excavations which may disturb the ground or groundwater, and any anticipated uses of groundwater, during the coming year.

The notification should stipulate that the letter or report that the property owners provide should state that, to the best of their knowledge, they have not violated any of the restrictions or covenants set forth in the initial deed. If any of the restrictions or covenants set forth in the initial deed have been violated, further explanation should be provided. A similar notification should be sent to Will County, regarding the landfill property; however, it should be worded differently, as there is not a requirement for such a report specified in the deed for that property.

It is recommended that the notifications explicitly state that compliance is required and if necessary enforcement through the civil courts may be pursued to ensure that land use

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restrictions are maintained and verified. It is recommended that all such notifications be sent out simultaneously and include a one-month response time in order to minimize the administrative burden of tracking compliance. A spreadsheet should be maintained to facilitate tracking of inbound and outbound correspondence and reports, requirements for follow-up and potential IC compliance issues and enforcement actions.

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5.0 PROGRESS SINCE LAST FIVE YEAR REVIEW

Source removal of impacted soils has been completed for all SRUs at Sites in the SOU. Interim and final remedies were started at several of the SRUs during the first Five-Year Review period, and were completed during this review period. Several others have been started and completed within this Second Five Year Review Period. According to the RAOs established in the June 2004 ROD, all actions required to achieve closure status for SRUs at Sites included in the SOU have been completed; however, Final Closure Reports for soils have not been approved for Sites L2, L3, L5, L23A, M1, M3, M4, M11, M12 and M13 as of the writing of this review.

During the First Five-Year Review issues and recommendation/follow-up actions were identified. A summary of these former issues and recommendations/follow-up actions and the actions taken since the last five-year review are provided in Table 16.

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Table 16: Actions Taken Since the Last Five-Year Review

Issues from Previous Review Recommendations/Follow-up Actions Current Site Status

Site M1 – 24, 1/4 inch diameter, holes in LLDPE liner were encountered during site inspection. One, 3 inch diameter, hole from burrowing rodent (mouse) located 11panels to the east of the western edge of Ash pile on North side. Two split seams (3inch tears) are located 7 panels to the east of the western edge of Ash pile on South

Repair split seams and burrowing rodent hole. Monitor any increase in size of the 24, 1/4 inch diameter, holes in liner.

IEPA notified the Army, by letter of July 24, 1998, that since the ash residues at M1 no longer exhibited the characteristic of reactivity (for which they were listed), they were not hazardous wastes regulated under 35 Illinois Administrative Code (IAC) 721.103(a)(2)(C). No RCRA hazardous waste was identified at Site M1.

side. Scenario was anticipated and addressed in the RD/RA Work plan.

Site M6 - Excavations below and around some of the building foundations were abandoned due to groundwater infiltration into the excavation area. Additional excavation activities will not be conducted at these locations to remove soils above RGs.

Excavations were backfilled in accordance with USEPA approved work plan therefore no further action is necessary scenario was anticipated and addressed in the RD/RA Work plan. Excavations were backfilled in accordance with USEPA approved work plan

RA activities have since been completed at Site M6. According to the RAOs set forth in the June 2004 ROD, Site M6 has achieved closure status for SRU1 and SRU3 soils as documented in the Final Closure Report, Site M6 (MWH, June 2006).

therefore no further action is necessary. Maintain current leachate collection RA activities have since been

Site M9 - Operation of leachate and disposal. Continue routine site completed at Site M9. According to the re-circulation system has been inspections to monitor any new RAOs set forth in the October 1998 permanently discontinued due to occurrences of leachate seepage ROD, Site M9 has achieved closure operational problems and from the existing cap. status for SRU6 soil as documented in maintenance issues. the Final M9 Remedial Action

Completion Report (MWH, March 2008).

1) Establish a roped area RA activities have since been Site M9 – One sinkhole (10ft surrounding the perimeter of the completed at Site M9. According to the diameter, 3ft depth) in the existing sinkhole to identify its location to RAOs set forth in the October 1998 cap. site workers. ROD, Site M9 has achieved closure

2) Monitor size and depth of sink- status for SRU6 soil as documented in hole. If increase in size or depth is the Final M9 Remedial Action observed, conduct activities to Completion Report (MWH, March repair. 2008).

RA activities have since been completed at Site M9. According to the

Site M9 – One 10 inch diameter hole created by a burrowing animal in the existing cap.

Repair burrow hole in existing cap.

RAOs set forth in the October 1998 ROD, Site M9 has achieved closure status for SRU6 soil as documented in the Final M9 Remedial Action Completion Report (MWH, March 2008). RA activities have since been

Site L1 – Site perimeter fencing does not have a pad lock on the main entrance gate.

Place a padlock on the main entrance gate.

completed at Site L1. According to the RAOs set forth in the June 2004 ROD, Site L1 has achieved closure status for SRU1 and SRU5 soils as documented in the Final Closure Report, Sites L1,

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Issues from Previous Review Recommendations/Follow-up Actions Current Site Status

L7, L8, L9, L10, L14, and M2 (MWH, October 2006).

Remedial actions at Site L3 have been Site L3 – Rear entrance gate to the Replace gate and padlock at rear completed, but the closure report was site has been destroyed. entrance to the site. not available during this review. The

site is now secure. RA activities have since been completed at Site L9. According to the

Site L9 – No gate is present at the entrance to the site.

Construct a gate/fencing or place "no entry" signs at the entrance to the site.

RAOs set forth in the June 2004 ROD, Site L9 has achieved closure status for SRU1 soils as documented in the Final Closure Report, Sites L1, L7, L8, L9, L10, L14, and M2 (MWH, October 2006). RA activities have since been completed at Site L10. According to the RAOs set forth in the June 2004

Site L10 – Gate along victory Close gate and place padlock to ROD, Site L10 has achieved closure drive is open and unlocked. secure site. status for SRU1 soils as documented in

the Final Closure Report, Sites L1, L7, L8, L9, L10, L14, and M2 (MWH, October 2006). RA activities have since been completed at Site L11. According to

Site L11 – Site perimeter fencing does not have a padlock on the main entrance gate.

Place a padlock on the main entrance gate.

the RAOs set forth in the October 1998 ROD, Site L11 has achieved closure status as part of the SOU as documented in the Final Closure Report – Sites L11/L16 (MWH, December 2003).

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6.0 FIVE-YEAR REVIEW PROCESS 6.1 Administrative Component The Second Five-Year Review of the SOU at JOAAP was performed by AEROSTAR, under contract to the USACE, on behalf of the United States Army. Representatives from the USEPA and IEPA were notified of the initiation of the second five-year review during monthly project management meetings.

Components of the Five-Year Review included:

� Community Involvement; � Document Review; � Data Review; � Site Inspection; � Local Interviews; and � Five-Year Review Report Development and Review.

The review team included members from the AEROSTAR project management and technical advisory staff with expertise in construction management, engineering, hydrology, chemistry, environmental regulations, and risk assessment. Mr. Thomas Barounis of the USEPA and Ms. Nicole Wilson of the IEPA assisted in the review as representatives for the support agencies.

The schedule of project activities extended from October 21, 2008 to May 4, 2009.

6.2 Community Involvement Community involvement through the RAB has been ongoing and the schedule for the Second Five Year Review was discussed informally during RAB meetings during the first half of 2008. In addition, correspondence between the regulators and the U.S. Army relating to the Five Year Reviews is copied to the RAB secretary.

A public notice of the availability of the Five Year Review and associated public comment process was posted in the weekly Wilmington, Illinois Free Press Advocate. Public notices were also published in the daily Joliet Herald News and Kankakee Daily Journal. The public notice was also published on the Joliet Herald News and Kankakee Daily Journal web sites. A copy of the public notice is presented in Attachment 8.

6.3 Document Review The Second Five-Year Review consisted of a review of relevant documents including remedial design reports, closure reports, work plans, O&M records, facility records, and the October 1998 and June 2004 RODs. Applicable RAOs, ARARS, and soil clean-up standards, as listed in the October 1998 and June 2004 RODs, were also reviewed. A list of documents that were reviewed during the Second Five-Year Review is presented in Attachment 3.

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6.4 Data Review

6.4.1 Data Review for Soil Operable Unit RA Activities Preliminary characterization and confirmation sampling activities have been conducted throughout the duration of RA activities within the SOU. Preliminary characterization sampling was conducted during the RI/ FS to delineate the horizontal and vertical extent of contamination at each site. Subsequent RA activities were conducted to remediate soils at the locations where COC above RGs were identified during the RI/FS process. Confirmation sampling was used to verify that the remaining soils in excavated areas did not exceed the RGs or TCLP standards set in the October 1998 and June 2004 RODs. Confirmation sampling for the excavated areas was conducted in accordance with the SOU SAPs.

Data from confirmation sampling results was reviewed for individual RA activities and/or sites. Data from USEPA and IEPA approved closure reports, construction completion reports, work plans, and data validation reports were used in the review to assess that RA activities satisfied RGs at each site. Results of the confirmation sampling activities are summarized in the closure reports developed during the RA operations at JOAAP.

6.4.2 Data Review for Site M4 Bioremediation Facility Operations Data reviewed for the development of this Second Five-Year Review is inclusive of information presented in the FY2000, FY2001, FY2002 Bioremediation Reports and the 2004 Incentive Fee Treatment Quantities Report prepared by MWH. Bioremediation Reports for FY2003 and FY 2004 were unavailable during the writing of this review. Bioremediation Reports for FY2005 through FY2007 were under production during the writing of this review.

Data included in the Bioremediation Reports relevant to the five-year review includes explosives concentrations in soil prior to, and following, treatment. Consistent with confirmation sampling at sites where RA activities have been conducted, pretreatment sample results indicate explosives concentrations in soil greater than the designated RGs for SRU1 and SRU3 soils.

All soil treatment has been completed. Approximately 165,769 tons of SRU1 and SRU3 soils have been successfully treated from May 2000 to December 2004. Post treatment sample results indicated SRU1 and SRU3 soils were successfully treated to meet RGs. Treatment of SRU5 soils was also conducted at the Site M4 BTF however; details pertaining to the treatment were unavailable during the writing of this review.

For detailed treatment information for all soils treated at the BTF, refer to Table 10.

6.5 Site Inspection Representatives from AEROSTAR (Gerald Girardot and Tim Cullen) conducted site inspections on October 22 and 23, 2008. The purpose of the inspections was to assess the current site conditions, evaluate the integrity of historical RA activities, evaluate current access controls and use restrictions at each respective site.

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Site inspections were conducted at Sites L3, M11 and M13 in accordance with the “Five-Year Review Site Inspection Checklist”, dated June 2002. These sites currently have complete or incomplete RA activities or O&M operations at the sites. Inspections of the active sites resulted in comprehensive overview of each site’s operations and effectiveness of the implemented remedy or O&M activity. Results of the site inspections at the sites indicated that the sites are being maintained in generally good conditions and the selected remedies are functioning as intended. Issues identified during the site inspection are discussed in Table 16 of Section 8.0. Recommendations for the issues identified are discussed in Table 17 of Section 9.0. Copies of the site inspection checklists for Sites L3, M11 and M13 are included in Attachment 5a, Attachment 5b, and Attachment 5c, respectively.

Results of the site inspections for all other sites in the SOU indicated that the sites where RA activities are complete have not been altered in a manner that could affect the protectiveness of the implemented remedy. Access controls have been effectively implemented at each RA site and are in good condition. Issues identified during the site inspection of RA sites are discussed in Table 16 of Section 8.0. Recommendations for the issues identified are discussed in Table 17 of Section 9.0. Site inspection observation forms for sites that have achieved closure status or are incomplete, are located in Attachment 5d.

6.6 Interviews Interviews were conducted with various parties affiliated with the JOAAP project and sites. An interview was conducted on October 21, 2008 with the RAB co-chair, Reverend Alvin Abbott. Discussion was directed toward the impacts on, and concerns of, the community in relationship to the historical, current and future activities at JOAAP. A copy of the interview questions and responses from Rev. Abbott are included in Attachment 6a.

Discussions were also conducted with JOAAP Site Manager, Mr. Arthur Holz from October 21 to October 23, 2008. Interview questions/discussions were directed toward the performance and management of the JOAAP project. A copy of the interview questions and responses from Mr. Holz are included in Attachment 6b.

An interview was conducted with the Waste Services Manager for Will County Waste Services, Mr. Dean Olson on October 22, 2008. Discussion and questions were directed toward assessing new information regarding site operations, evidence of contamination, or changes regarding enforcement of institutional and access controls at the Will County Landfill. A copy of the interview questions and responses from Mr. Dean Olson are included in Attachment 6c.

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7.0 TECHNICAL ASSESSMENT This section presents the technical assessment of the final remedies selected in the October 1998 ROD and the June 2004 ROD for SOU sites at JOAAP in accordance with the Comprehensive Five-Year Review Guidance (USEPA, 2001).

7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS?

7.1.1 SRU1 Soils

7.1.1.1 Sites L1, L2, L7, L8, L9, L10, L14, M2, and M3 The Excavation and Bioremediation remedy selected for Sites L1, L2, L7, L8, L9, L10, L14, M2, and M3 (SRU1) is identified as a completed remedial action at the sites and RGs have been achieved for soil media affected by the SRU1 COC. The results of the Second Five-Year Review indicate that the excavation and bioremediation activities successfully functioned to satisfy the intended RAOs stated in the June 2004 ROD.

Costs or issues associated with monitoring and performance are not anticipated. Remedial action activities are complete, and RGs for soil have been met.

Existing site fencing at the LAP area serves as a deterrent to unauthorized entry to the LAP sites. Entry to the sites will remain restricted until the property transfer to the future owners is complete. When the property transfers are complete, these sites will be part of the MNTP and for recreational use only.

7.1.1.2 Site L16 The excavation and bioremediation remedy selected for Site L16 (SRU1) is identified as a completed remedial action at the site where RGs have been achieved for soil media affected by the COC. Remedial action activities have also removed all MEC waste from the site. The results of the First Five-Year review indicate that the remedy functioned to satisfy the intended RAOs stated in the October 1998 ROD.

Costs or issues associated with monitoring and performance are not anticipated. RA activities are complete, RGs for soil have been met, and MEC items have been cleared. Site L16 has been transferred to the JADA. Site L16 is restricted to industrial use only.

7.1.1.3 Site M6 The majority of soils at Site M6, as characterized in the RI/FS, were determined to be SRU1 soils. The selected remedy at Site M6, for both SRU1 and SRU3 soils, was the same excavation

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and bioremediation. For these reasons, the discussion pertaining to SRU3 soils at Site M6 has been summarized under the SRU1 heading.

The excavation and bioremediation remedy selected for Site M6 (SRU1 and SRU3) is identified as a completed remedial action where the RGs have been achieved for soil media affected by the COC. The results of the Second Five-Year Review indicate that the remedy functioned to satisfy the intended RAOs stated in the October 1998 ROD.

Costs or issues associated with monitoring and performance are not anticipated. RA activities are complete, RGs for soil have been met

Perimeter fencing does not exist at Site M6. Chain-linked fence was constructed around open excavation areas that were not backfilled following construction. During the site visit in October 2008, the southern open excavation area was only partially fenced on the west side of the excavation and the fencing at the other open excavation area was intact, but the gate was unlocked. A berm surrounds the excavations preventing direct access to the excavations by the general public, the roads that access the areas are gated and locked, and the area is patrolled by security guards. Vehicular access points to the site have “warning” and “government property” signs clearly visible. Access to the site at vehicular access points is restricted, when not in use, by posting warning signs mounted on a gate across the site entrance/exit. RA activities at Site M6 are complete.

7.1.1.4 Site M7 The excavation and bioremediation remedy selected for Site M7 (SRU1) is identified as a completed remedial action at the site and RGs have been achieved for soil media affected by the COC. The results of the First Five-Year Review indicate that the excavation and bioremediation activities successfully functioned to satisfy the intended RAOs stated in the October 1998 ROD.

Costs or issues associated with monitoring and performance at Site M7 are not anticipated. Remedial action activities are complete and RGs for soil have been met, therefore further costs associated with additional soil removal will not be incurred.

Perimeter fencing does not exist at Site M7; however, the roads that access the areas are gated and locked, and the area is patrolled by security guards. Entry to the site will remain restricted until the property transfer to the future owners is complete. Vehicular access points to the site have “warning” and “government property” signs clearly visible. Access to the site at vehicular access points is restricted, when not in use, by posting warning signs mounted on a gate across the entrance/exit.

7.1.2 SRU2 Soils

7.1.2.1 Sites L2, L23A, M3, M4, and M12 The majority of soils at Site M3, as characterized in the RI/FS, were determined to be SRU2 soils. SRU2 and SRU3 soils at site M3 were excavated and disposed of together. For these

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reasons, the discussion pertaining to SRU3 soils at Site M3 has been summarized under the SRU2 heading.

The majority of soils at Site M12, as characterized in the RI/FS, were determined to be SRU2 soils. Due to their small volume, SRU7 soils were mixed with the SRU2 soils prior to disposal. For these reasons, the discussion pertaining to SRU7 soils at Site M3, has been summarized under the SRU2 heading.

The Excavation and Disposal remedy selected for Sites L2, L23A, M3, M4, and M12 (SRU 2, 3, and 7) is identified as a completed remedial action at the site and RGs have been achieved for soil media affected by the COC. The results of the Second Five-year Review indicated that the excavation and disposal activities successfully functioned to satisfy the intended RAOs stated in the June 2004 ROD.

Costs or issues associated with monitoring and performance are not anticipated. Remedial action activities are complete; RGs for soil have been met.

Existing site fencing serves as a deterrent to unauthorized entry to the sites. Entry to the sites will remain restricted until the property transfer to the future owners is complete. When the property transfers are complete, these sites will be part of the MNTP and for recreational use only.

7.1.2.2 Sites L3 and L5 The Excavation and Disposal remedy selected for Sites L3 and L5 is identified as a completed remedial action however; the closure reports for these sites have not been finalized as of the writing of this review.

Soil grading, berming, and silt fencing was to be implemented to minimize migration of contaminants in surface water runoff from excavation areas. During the site visit in October 2008, vegetative cover was not established in the excavation area east of the onsite buildings and no silt fence was in place at Site L5.

Existing site fencing at the LAP area serves as a deterrent to unauthorized entry to the site. Entry to the site will remain restricted until the property transfer to the future owners is complete. When the property transfers are complete, these sites will be part of the MNTP and for recreational use only.

7.1.2.3 Sites L11 The Excavation and Disposal remedy selected for Site L11 (SRU2) is identified as a completed remedial action at the site and RGs have been achieved for soil media affected by the COC. Remedial action activities have also removed all MEC waste from the site. The results of the First Five-year Review indicated that the excavation and disposal activities successfully functioned to satisfy the intended RAOs stated in the October 1998 ROD.

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Costs or issues associated with monitoring and performance are not anticipated. Remedial action activities are complete, RGs for soil have been met, and MEC items have been cleared.

Existing site fencing serves as a deterrent to unauthorized entry to the site. Site L11 has been transferred to the State of Illinois. Site L11 is restricted to industrial use only.

7.1.3 SRU3 Soils

7.1.3.1 Sites L3 The Excavation and Disposal remedy selected for Site L3 is identified as a completed remedial action however; the closure report for Site L3 has not been finalized and was not available as of the writing of this review.

Soil grading, berming, and silt fencing was to be implemented to minimize migration of contaminants in surface water runoff from excavation areas. During the site visit in October 2008, vegetative cover was not established in the excavation area east of the onsite landfill and no silt fence was in place.

Existing site fencing at the LAP area serves as a deterrent to unauthorized entry to the site. Entry to the site will remain restricted until the property transfer to the future owners is complete. When the property transfer is complete, the site will be part of the MNTP and for recreational use only.

7.1.3.2 Sites M5 The majority of soils at Site M5, as characterized in the RI/FS, were determined to be SRU3 soils. Furthermore, due to the relatively low concentrations of lead in the SRU3 soils, the selected remedy for SRU3 soils was designated as “Bioremediation and Disposal”. For these reasons, the discussion pertaining to SRU1 soils at Site M5, has been summarized under the SRU3 heading.

The bioremediation and disposal remedy selected for Site M5 (SRU3 and SRU1) is identified as a completed remedial action at the site and RGs have been achieved for soil media affected by the COC. The results of the First Five-Year Review indicate that the bioremediation and disposal activities successfully functioned to satisfy the intended RAOs stated in the October 1998 ROD.

Costs or issues associated with monitoring and performance at Site M5 are not anticipated. Remedial action activities are complete and RGs for soil have been met, therefore further costs associated with additional soil removal and monitoring will not be incurred. The State of Illinois acquired the deed for the land area of Site M5 in August 2000. Following the land transfer, the State of Illinois sold the site to CenterPoint Properties. The site has been developed into an intermodal rail facility and is currently operated by BNSF. Access to the site is restricted by fencing installed by BNSF.

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7.1.4 SRU4 Soils

7.1.4.1 Sites L1, L7, L8, L9, L10, and L17 The Excavation and Disposal remedy selected for Sites L1, L7, L8, L9, L10, and L17 (SRU4) is identified as a completed remedial action at the site and RGs have been achieved for soil media affected by the SRU4 COC. The results of the First Five-Year Review indicate that the excavation and disposal activities successfully functioned to satisfy the intended RAOs stated in the October 1998 ROD.

Costs or issues associated with monitoring and performance are not anticipated. Remedial action activities are complete, and RGs for soil have been met.

Existing site fencing at the LAP area serves as a deterrent to unauthorized entry to the sites. Entry to Sites L1, L7, L8, L9, and L10 will remain restricted until the property transfers to the future owners are complete. When the property transfers are complete, Sites L1, L7, L8, L9, and L10 will be part of the MNTP and for recreational use only. Site L17 has been transferred to the State of Illinois. Site L17 will be restricted to industrial use only.

7.1.4.2 Sites L5 The Excavation and Disposal remedy selected for Site L5 is identified as a completed remedial action however; the closure report for Site L5 has not been finalized as of the writing of this review.



7.1.5 SRU5 Soils

7.1.5.1 Site L1 The excavation and bioremediation remedy selected for Site L1 (SRU5) is identified as a completed remedial action at the site where RGs have been achieved for soil media affected by the COC. The results of the Second Five-Year review indicate that the remedy functioned to satisfy the intended RAOs stated in the June 2004 ROD.

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Costs or issues associated with monitoring and performance are not anticipated. RA activities are complete, RGs for soil have been met.

Existing site fencing serves as a deterrent to unauthorized entry to the site. Entry to the site will remain restricted until the property transfer to the future owners is complete. When the property transfer is complete, the site will be part of the MNTP and for recreational use only.

7.1.5.2 Site L5 The Excavation and Bioremediation remedy selected for Site L5 is identified as a completed remedial action; however, the closure report for Site L5 has not been finalized as of the writing of this review.



7.1.6 SRU6 Soils

7.1.6.1 Sites L3 and M13 Capping and Institutional Controls remedy selected at Sites L3 and M13 are identified as a complete remedial action; however, approval for final closure has not been received.

Soil monitoring will not be necessary other than inspection of erosion control measures. Long-term O&M costs will include landfill cap inspection and maintenance costs. Equipment breakdowns should not create any protectiveness issues. Soil grading, berming, and silt fencing will be implemented to minimize migration of contaminants in surface water runoff from excavation areas.

During the site visit by AEROSTAR in October 2008, minor animal burrowing (~3 inch diameter) was evident in the southeastern area of the M13 landfill cap.

Existing site fencing at the Site M13 Landfill serves as a deterrent to unauthorized entry to the site. The future property owner will be required to keep the site fencing in place. When the property transfer is complete, Site L3 will be part of the MNTP and for recreational use only and Site M13 will be restricted to industrial use only.

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7.1.6.2 Site M11 The Capping and Institutional Controls remedy selected for Site M11 is identified as a completed remedial action; however, approval for final closure has not been received.

Soil monitoring is not necessary other than inspection of erosion control measures. Long-term O&M costs will include landfill cap inspection and maintenance costs. During the site visit by AEROSTAR in October 2008, a small area of standing water with an oily/rusty sheen (leachate?) was noticed at the toe of the rip-rap on the west-northwest side of the M11 landfill.

Existing site fencing at the Site M11 Landfill serves as a deterrent to unauthorized entry to the site. The future property owner will be required to keep the site fencing in place. When the property transfer is complete, the site will be part of the MNTP and for recreational use only.

7.1.6.3 Site M1 The Soil Excavation and Disposal remedy at Site M1 has been completed; however final closure has not been received.

Existing site fencing serves as a deterrent to unauthorized entry to the site. Entry to the site will remain restricted until the property transfer to the future owners is complete. When the property transfer is complete, the site will be part of the MNTP and for recreational use only.

7.1.6.4 Sites L4 and M9 The Soil Excavation and Disposal and Institutional Controls remedy selected for Sites L4 and M9 is identified as a completed remedial action at the site where RGs have been achieved for soil media affected by the COC.

Costs or issues associated with monitoring and performance are not anticipated. RA activities are complete; RGs for soil have been met.

Existing site fencing serves as a deterrent to unauthorized entry to the site. Entry to the site will remain restricted until the property transfer to the future owners is complete. When the property transfer is complete, Site L4 will be part of the MNTP and for recreational use only and Site M9 will be restricted to industrial use only.

7.1.7 SRU7 Soils

7.1.7.1 Site M8 The Excavation and Disposal remedy selected for Site M8 is identified as a completed remedial action where SRU7 (raw surficial sulfur) soils have been removed from the site. The surficial sulfur was removed during liquidation activities, prior to the transfer of the property to the State of Illinois. This site is considered protective of human health and the environment.

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According to the FOST, February 1999, there were no exceedances of soil industrial RGs in all of Site M8. On August 10, 2000, the site was transferred to the State of Illinois for inclusion into an industrial park facility. Following the land transfer, the State of Illinois sold the site to CenterPoint Properties. Subsequent site activities included the construction of an intermodal rail facility currently operated by BNSF. Existing site fencing, constructed by BNSF, serves as a deterrent to unauthorized entry. CenterPoint Properties submits certification of compliance for implementation of institutional controls, specified in the property deed, to the Army on an annual basis. Copies of the annual certification are included as Attachment 7.

7.1.8 Site M4 Bioremediation Facility The bioremediation remedy selected for SRU1 and SRU3 soils functioned as intended by the October 1998 ROD. SRU1 and SRU3 soils from Sites M5, M6 and M7 have been successfully treated to achieve RGs for the soil media affected by the COC. Efficiencies realized during the operation and maintenance of the BTF included:

� Pre-blending of the 3 amendments components � Post treatment sample frequency reduction for Site M6 SRU1 soil (from 12 to 8) � Increase space available for treatment by 33% � Increased and refined physical/chemical monitoring of windrows during active treatment

to insure optimal conditions exist for bio-activity

Bioremediation of SRU1, SRU3, and SRU5 JOAAP soils was conducted through 2007. Following completion of bioremediation activities, the M4 BTF was decommissioned.

7.1.9 No Further Action Sites

Institutional controls in the form of deed restrictions to limit land use to industrial purposes are being effectively implemented at NFA Sites (L6 and M16) where COC are present at levels that do not allow for unlimited use and unrestricted access. Sites L6 and M16 have been transferred.

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF THE REMEDIAL SELECTION STILL VALID?

There have been no changes in the physical conditions at JOAAP that would affect the protectiveness of the remedies.

There have been no changes to the ARARs and no new standards or TBDs enforced that would affect the protectiveness of the remedies. A summary of ARARs identified in the October 1998 and June 2004 RODs is located in Attachment 4.

There have been no significant changes to the exposure pathways or toxicity factors for the COC used in the baseline risk assessment. The assumptions used to develop the baseline risk

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assessment are considered conservative, reasonable and appropriate for evaluating and developing site-specific, risk-based cleanup levels. The sites reviewed during this Second Five-Year Review have been categorized with the RGs set in the October 1998 ROD and June 2004 ROD. No change to the assumptions used to generate the industrial RGs is warranted. There has been no significant change in the standardized risk-assessment methodology that could affect the protectiveness of the selected remedies.

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?

No additional ecological targets were identified during five-year review process. Weather related events are not expected to affect the protectiveness of the remedies. There is no other information that calls into question the protectiveness of the remedies.

7.4 TECHNICAL ASSESSMENT SUMMARY

According to construction and O&M records, data reviewed, site inspections, and interviews, the selected remedies at all sites discussed in this Second Five-Year Review have functioned as intended by the October 1998 ROD and the June 2004 ROD. There have been no changes to physical conditions that would affect the protectiveness of the remedies. Site-specific ARARs stated in the October 1998 ROD and the June 2004 ROD at each site have been met or are expected to be met upon completion. There have been no significant changes to the toxicity factors for the COC that were used in the baseline risk assessment, and there have been no significant changes to the standardized risk assessment methodology that could affect protectiveness of the remedies. There is no other information that calls into question the protectiveness of the remedies.

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8.0 ISSUES This Second Five-Year Review identified five issues related to site operations, which are listed below. None of the issues identified affect the long-term protectiveness of the selected remedy at those sites. A summary of the issues is listed below in Table 17.

Table 17: Issues Identified During Second Five-Year Review

Affects Protectiveness

(Y/N)Issues Current Future

Site L3 – The area east of the landfill has no vegetative cover and no silt fence in place to control erosion.

Y Y

Site L5 - PCB excavation area shown on Figure 3-7 of L5 Draft Closure Report (MWH, March 2008) is not evident as depicted. No significant vegetative cover is established in the excavation area east of the onsite buildings and no silt fence is in place.

Y Y

Site M11 - The small area of standing water with an oily/rusty sheen at the toe of rip-rap on the west-northwest side of the landfill may be leachate seeping from the landfill. Vegetative cover on cap is excessive, inhibiting inspection of cap integrity. Vegetation beyond rip-rap is not established. Minor surface erosion on the landfill cap was noticed during an O&M inspection. No lock on gate.

Y Y

Site M13 – Minor animal burrowing (~3 inch diameter) evident in the southeastern area of cap. Vegetative cover on cap is excessive, inhibiting inspection of cap integrity. Minor surface erosion on the landfill cap and a small surveyor hole were noticed during an O&M inspection. No lock on gate.

Y Y

General - The owners of the Prologis Industrial Park should provide documentation to the U.S. Army, similar to that provided by CenterPoint Industrial Park, to verify that they understand and are in compliance with the institutional controls and deed restrictions placed on their property.

Y Y

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General - The Second Five-Year Reviews for Soil and Groundwater Y Y were prepared in the same format as the initial Five-Year Reviews. Because remedial actions for the vast majority of Soil Operable Unit Sites were completed during the time between the First and Second Five Year Reviews, combining the documents for the SOU and GOU for the next Five Year Review should be considered to avoid unnecessary redundancy and present the data in an integrated format.

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9.0 RECOMMENDATION AND FOLLOW-UP ACTIONS The following recommendations and follow-up actions (Table 18) are suggested for the issues identified during the Second Five-Year Review.

Table 18: Recommendations and Follow-up Actions

Site Issues Recommendations/ Follow-up Actions

Party Responsible

Oversight Agency

Milestone Date

Follow-up Actions: Affects

Protectiveness (Y/N)

Current Future

L3

No vegetative cover or silt fence in place to control erosion.

Install silt fencing around the area without established vegetation to the east of landfill and hydroseed.

U.S. Army USEPA 2009 Y Y

L5

No vegetative cover or silt fence in place to control erosion.

Install silt fencing around the area without established vegetation to the east of the onsite buildings and hydroseed.


M11

Possible seepage of leachate. Excessive vegetative coverage on cap. No lock on gate.

Inspect the cap/ liner on the west-northwest side of the landfill. Collect a surface water sample and soil sample in the vicinity of the oily sheen to be analyzed for any COC that may be present at the landfill. Mow vegetation on the landfill cap as needed. Backfill and seed as necessary to eliminate minor surface erosion. Place lock on gate.


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Site Issues Recommendations/ Follow-up Actions

Party Responsible

Oversight Agency

Milestone Date

Follow-up Actions: Affects

Protectiveness (Y/N)

Current Future

M13

Excessive vegetative coverage on cap. Minor animal burrowing on cap. Minor surface erosion on cap. No lock on gate.

Mow vegetation on the landfill cap as needed. Repair animal burrow holes in cap. Backfill and seed as necessary to eliminate minor surface erosion and the small surveyor hole. Place lock on gate.


General

Lack of documentation by Prologis Industrial Park regarding compliance with institutional controls and deed restrictions.

Perform interviews with new owners, operators, or managers, of transferred properties to ensure deed restrictions are being followed and institutional controls implemented at the sites are still effective.

U.S. Army IEPA/ USEPA 10/30/09 Y Y

General

Potential redundancy in future five year reviews.

Consider combining the documents for the SOU and GOU for the next Five Year Review.

U.S. Army USEPA 05/5/14 N N

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10.0 PROTECTIVE STATEMENTS

SRU1 Soils - Bioremediation Sites L1, L2, L7, L8, L9, L10, L14, M2, M3, M5, M6, M7, and L16

Remedial actions at Sites M5, M7, and L16 were completed during the First Five-Year Review. Sites L1, L2, L7, L8, L9, L10, L14, M2, M3 and M6 were completed during the Second Five-Year Review. Potential threats at the sites have been addressed through excavation and bioremediation of explosives contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU2 Soils – Excavation and Disposal Sites L2, L11, L23A, M3, M4, and M12

Remedial action at Site L11 was completed during the First Five-Year Review. Sites L2, L23A, M3, M4, and M12 were completed during this Second Five-Year Review. Potential threats at the sites have been addressed through excavation and disposal of metals contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Sites L3 and L5

Remedial actions at Sites L3 and L5 have been completed, but the closure reports were not available during this review. The selected remedy included excavation and disposal of metals contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU3 Soils – Bioremediation and Disposal, and Excavation and Disposal Sites M3, M5, and M6

Remedial actions at Site M5 were completed during the First Five-Year Review. Sites M3 and M6 were completed during the Second Five-Year Review. Potential threats at the sites have been addressed through excavation and bioremediation of metals and explosives contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and

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June 2004 RODs have been met and the sites are protective of human health and the environment.

Site L3Remedial actions at Site L3 have been completed, but the closure report was not available during this review The selected remedy included excavation and disposal of metals contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment. .

SRU4 Soils – Excavation/Incineration and Disposal Sites L1, L7, L8, L9, L10, and L17

Remedial actions at Sites L1, L7, L8, L9, L10, and L17 were completed during the First Five-Year Review. Potential threats at the sites have been addressed through excavation and disposal of PCB-contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Site L5 Remedial actions at Site L5 have been completed, but the closure report was not available during this review. The remedy at Site L5 is expected to be protective of human health and the environment upon completion. The selected remedy included excavation and disposal of PCN contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU5 Soils – Excavation and Bioremediation Site L1

Remedial action at Site L1 was completed during the First Five-Year review. Potential threats at the site have been addressed through excavation and bioremediation of TPH contaminated soils, and implementation of institutional controls in the form of land use restrictions (for lands to be transferred within the federal government). Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Site L5 Remedial actions at Site L5 have been completed, but the closure report was not available during this review. The selected remedy included excavation and bioremediation of TPH contaminated soil and implementation of institutional controls in the form of land use restrictions (for lands to be transferred within the federal government). Current data indicates that the RGs established

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in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

SRU6 Soils – Excavation and Disposal Sites L4, M9, and M1

The remedy for Sites L4, M9, and M1 is complete. Potential threats at the sites have been addressed through excavation and disposal of SRU6 contaminated soils, and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). The closure report for M1 was not available during this review. Current data indicates that the RGs established in the October 1998 and June 2004 RODs have been met and the sites are protective of human health and the environment.

Sites L3, M11, and M13 Remedial actions at Sites L3 and M13 have been completed, but the closure reports were not available during this review. In the interim, exposure pathways that could result in unacceptable risks are being controlled through access controls in the form of fencing. The selected remedy included capping or excavation and disposal of SRU6 soils and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Further assessment is needed at Site M11 to address the oily sheen noticed at the edge of the rip-rap.

SRU7 Soils – Removal and Recycle or Disposal Sites M8 and M12 Remedial actions at Sites M8 and M12 were completed during the First Five-Year Review. Impacted soils at the site have been addressed through excavation and disposal of surficial sulfur and implementation of institutional controls in the form of deed restrictions (for lands transferred out of federal ownership) or land use restrictions (for lands transferred within the federal government). Sites M8 and M12 are considered to be protective of human health and the environment.

No Further Action Sites Site L6 Removal actions at Site L6 are complete. Potential threats at the site have been addressed through excavation and disposal of impacted soils, and implementation of institutional controls. Land use restrictions limiting land use for industrial purposes are being implemented. Current data indicates that the RGs established in the October 1998 are satisfied and the site is protective of human health and the environment.

Site M16 Deed restrictions limiting land use for industrial purposes are being enforced. Current data indicates that the RGs established in the October 1998 are satisfied and the site is protective of human health and the environment.

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11.0 NEXT REVIEW

The next five-year review period for the SOU will begin on May 5, 2009. The Third Five-Year Review Report will be due five years from the approval date of this report.

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